HomeMy WebLinkAbout20102324.tiff STATE OF COLORADO
Bill Ritter,Jr.,Governor
Ned Calonge,M.D., Interim Executive Director .00 cot°
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Dedicated to protecting and improving the health and environment of the people of Colorado �/'
4300 Cherry Creek Dr.S. Laboratory Services Division *f **
Denver,Colorado 80246-1530 8100 Lowry Blvd. Jen♦
Phone(303)692-2000 Denver,Colorado 80230-6928
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado of Public Health
http://www.cdphe.state.co.us and Environment
September 27, 2010
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
On October 1, 2010, the Air Pollution Control Division will publish a public notice for Thermo Power and Electric,
LLC in The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies
of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be
available for public inspection for a period of thirty (30) days from the date the public notice is published. Please
send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health&Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Jacquie N. Barela
Regards,
Jacqueline N. Barela
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
()t )()C Qkoby 2010-2324
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5 - ID
NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING
PERMIT WARRANTING PUBLIC COMMENT
NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air
Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source
of air pollution:
Applicant' Thermo Power and Electric, LLC
510 18th Street
Greeley, CO 80631
Facility: Thermo Power and Electric, LLC- Greeley Facility
510 18th Street
Greeley, CO 80631
Thermo Power and Electric, LLC has applied for an Renewal Operating Permit for their facility in Weld County, CO. This facility
consists of two combustion turbines used to generate steam and electricity for sale. The primary fuel for these units is natural gas,
with distillate fuel oil used as a back-up fuel. A copy of the applications, including supplemental information, the Division
analysis, and a draft of the Renewal Operating Permit 95OPWE001 has been filed with the Weld County Clerk's office. Based on
the information submitted by the applicant,the Division has prepared the draft renewal operating permit for approval. Any
interested person may contact Jacqueline Joyce at the Division at 303-692-3267 to obtain additional information. Any interested
person may submit written comments to the Division concerning 1)the sufficiency of the preliminary analysis, 2) whether the
permit application should be approved or denied, 3)the ability of the proposed activity to comply with applicable requirements, 4)
the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other
appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment
hearing before the Colorado Air Quality Control Commission (Commission). If requested,the hearing will be held before the
Commission at their regularly scheduled meeting within 60 days of its receipt of the request for a hearing unless a longer time
period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting
the hearing, 2)state his or her address and phone number, and 3) state the reason(s)for the request,the manner in which the
person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented.
The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the -
date of this Notice.
RELEASED TO: The Greeley Tribune on PUBLISHED: October 1, 2010
September 27, 2010
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 95OPWE001 AIRS ID#: 1230126 DATE: September 27, 2010
APPLICANT: Thermo Power and Electric LLC—Greeley REVIEW ENGINEER: Jacqueline Joyce
SOURCE DESCRIPTION
Thermo Power and Electric LLC has applied for renewal of their Operating Permit issued for the Greeley facility located at
510 18th Street in Greeley Colorado on the University of Northern Colorado campus in Weld County. This facility consists
of two combustion turbines used to generate steam and produce electricity for sale and is classified under SIC 4931. This
facility is located in an area classified as attainment/maintenance for carbon monoxide (CO). Under that classification, all
SIP-approved requirements for CO will continue to apply in order to prevent backsliding under the provisions of Section
1100) of the Federal Clean Air Act. This area is classified as non-attainment for ozone and is part of the 8-hr Ozone
Control Area as defined in Regulation No. 7, Section II.A.1. This source is a major stationary source with respect to
Prevention of Significant Deterioration (PSD) review and non-attainment area new source review(NANSR)requirements.
Wyoming, an affected state is within 50 miles of this facility. Rocky Mountain National Park, a Federal Class I designated
area, is within 100 km of this facility. This source is not subject to the Accidental Release provisions of section 112(r) of
the Federal Clean Air Act. In addition, although the combustion turbines are equipped with steam injection to control NOx
emissions they are exempt from the compliance assurance monitoring (CAM) requirements in 40 CFR Part 64 because at
the time the CAM plan was required the Title V permit specified a continuous compliance determination method (§
64.2(b)(1)(vi)).
FACILITY EMISSION SUMMARY
Potential to Emit(tons/yr)
Emission Unit PM PM10 SO2 NOx CO VOC HAPS
Turbine (T001) 20.8 20.8 10 535.5 45 6.24 2.6
Turbine (T002) 20.8 20.8 10 535.5 45 6.24 2.6
Total 41.6 41.6 20 1,071. 90 12.48 5.2
Actual Emissions (tons/yr)
Emission Unit PM PM10 SO2 NOx CO VOC HAPS*
Turbine (T001) 3.4 3.4 1.6 88.2 7.4 1.0 0.16
Turbine (T002) 3.7 3.7 1.8 95.9 8.1 1.1 0.17
Total 7.1 7.1 3.4 184.1 15.5 2.1 0.33
*only formaldehyde emissions were above the APEN de minimis level.
EMISSION SOURCES
The following discussion identifies the changes that were made in the renewal permit.
Combustion Turbines— Based on EPA's response to a petition on another Title V permit, minor language changes were
made to various permit conditions to clarify that only natural gas is used for permit conditions that rely on fuel restriction for
the compliance demonstration. The frequency for performance testing was revised to every five years (affects both
Section II, Conditions 1 (combustion turbines) and 3 (performance test requirements)).
Portable Monitoring Requirements—The portable monitoring language was revised to reflect the most recent version.
Emergency Generator and Emergency Fire Water Pump Engine-The diesel fired engines driving an emergency
generator and an emergency fire water pump had previously been included in the insignificant activity list in Appendix A of
the permit. However due to recent revisions to the requirements in 40 CFR Part 63 Subpart ZZZZ (National Performance
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) these engines are now
subject to requirements in 40 CFR Part 63 Subpart ZZZZ and can no longer be considered insignificant activities. The
engines must comply with work practice standards in 40 CFR Part 63 Subpart ZZZZ beginning May 3, 2013. The engines
and the appropriate applicable requirements for these engines have been included in Section 11.5 of the permit.
ALTERNATIVE OPERATING SCENARIOS
The alternative operating scenario (AOS)was revised to reflect the most recent version.
INSIGNIFICANT ACTIVITY LIST
The emergency generator and emergency fire water pump engines were removed from the insignificant activity list. They
are now included in Section II of the permit.
PERMIT SHIELD
No additional non-applicable requirements were included in the permit shield.
TECHNICAL REVIEW DOCUMENT
For
RENEWAL of OPERATING PERMIT 95OPWE001
Thermo Power and Electric LLC — Greeley Facility
Weld County
Source ID 1230126
Prepared by Jacqueline Joyce
June 2010
Revised September 2010
I. Purpose:
This document will establish the basis for decisions made regarding the applicable
requirements, emission factors, monitoring plan and compliance status of emission units
covered by the renewed operating permit proposed for this site. The current Operating
Permit was issued January 1, 2006. The expiration date for the permit is January 1,
2011. This document is designed for reference during the review of the proposed
permit by the EPA, the public, and other interested parties. The conclusions made in
this report are based on information provided in the renewal application submitted
August 10, 2009, comments on the draft permit and technical review document received
on September 8, 2010, previous inspection reports and various e-mail correspondence,
as well as telephone conversations with the applicant. Please note that copies of the
Technical Review Document for the original permit and any Technical Review
Documents associated with subsequent modifications of the original Operating Permit
may be found in the Division files as well as on the Division website at
http://www.cdphe.state.co.us/apiTitlev.html.
Any revisions made to the underlying construction permits associated with this facility
made in conjunction with the processing of this operating permit application have been
reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction
Permits, and have been found to meet all applicable substantive and procedural
requirements. This operating permit incorporates and shall be considered to be a
combined construction/operating permit for any such revision, and the permittee shall
be allowed to operate under the revised conditions upon issuance of this operating
permit without applying for a revision to this permit or for an additional or revised
construction permit.
II. Description of Source
This facility consists of a cogeneration facility defined under Standard Industrial
Classification 4931. Electricity for sale is produced by two (2) combustion turbines and
a steam turbine. Each combustion turbine serves a generator rated at 42.5 MW (name-
plate) and the steam turbine generator is rated at 16.3 MW (name-plate).
Page 1
The facility is located at 510 18th Street, in Greeley, CO on the University of Northern
Colorado (UNC) Campus. This facility is located in an area classified as
attainment/maintenance for carbon monoxide (CO). Under that classification, all SIP-
approved requirements for CO will continue to apply in order to prevent backsliding
under the provisions of Section 110(1) of the Federal Clean Air Act. This Area is
classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
Wyoming, an affected state, is within 50 miles of the facility. Rocky Mountain National
Park, a federal Class I area is within 100 km of this facility.
Based on the information provided in the renewal application, no changes have been
made to any of the significant emission units.
The summary of emissions that was presented in the Technical Review Document
(TRD) for the renewal permit has been reproduced here. Since there have been no
changes to permitted emission and/or fuel consumption limitations and no new emission
units have been added to the facility, the potential to emit (PTE) has not changed. Both
potential and actual emissions (in tons per year) at the facility are as follows:
Potential to Emit(tons/yr)
Emission Unit PM PM10 SO2 NOx CO VOC HAPS
Turbine (T001) 20.8 20.8 10 535.5 45 6.24 See Table
Turbine (T002) 20.8 20.8 10 535.5 45 6.24 on Page 8
Total 41.6 51.6 20 1,071. 90 12.48 5.2
Actual Emissions (tons/yr)
Emission Unit PM PM10 SO2 NOx CO VOC HAPS*
Turbine (T001) 3.4 3.4 1.6 88.2 7.4 1.0 0.16
Turbine (T002) 3.7 3.7 1.8 95.9 8.1 1.1 0.17
Total 7.1 7.1 3.4 184.1 15.5 2.1 0.33
*only formaldehyde emissions were above the APEN de minimis level.
The criteria pollutant PTE shown above is based on permitted emission limits for the
turbines. Note that there are no permitted emission limits for PMio for the turbines,
PM10 is presumed to equal PM.
Actual emissions are based on the information provided in the APENs included in a
letter dated May 16, 2006 (2005 data).
The breakdown of HAP emissions by emission unit and individual HAP is provided on
page 8 of this document. The PTE of HAP emissions is based on emission factors
(formaldehyde from AP-42 and others from the 8/22/03 EPA memo for turbines),
permitted fuel consumption limits and a natural gas heat value of 1020 Btu/SCF.
Page 2
MACT Requirements
Although the facility is not a major source for HAPS, the EPA has been promulgating
rules for area sources (sources that are not major), those requirements that could
potentially apply to this facility are discussed below:
Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63
Subpart HHHHHH)
The final rules for paint stripping and miscellaneous surface coating were published in
the Federal Register on January 9, 2008 and apply to area sources that perform paint
stripping operations using methylene chloride, spray application of coatings to motor
vehicles and mobile equipment and spray application of coatings that contain the target
HAPS (chromium, lead, manganese, nickel or cadmium). As indicated in 40 CFR Part
63 § 63.11170(a)(2) and (3), spray applications (to motor vehicles and using coatings
that contain the target HAPS) that meet the definition of facility maintenance are not
subject to the requirements in this rule. The Division considers that any spray coatings
of motor vehicles and mobile equipment and spray application of coatings that contain
the target HAP at this facility would meet the definition of facility maintenance. The
source indicated that none of the paint stripping chemicals used at the facility contain
methylene chloride; therefore, the provisions in 40 CFR Part 63 Subpart HHHHHH do
not apply.
Reciprocating Internal Combustion Engines (RICE) (40 CFR Part 63 Subpart ZZZZ)
Final revisions to the RICE MACT were published in the Federal Register on March 3,
2010 and these revisions address existing (commenced construction prior to June 12,
2006) compression ignition engines at area sources. The insignificant activity list
indicates that there are diesel-fired engines driving a generator and a fire pump at the
facility. Both engines are considered emergency engines. Since these engines were in
the January 1, 2006 Title V renewal permit, these engines are existing engines and are
subject to requirements in MACT ZZZZ. Since these engines are considered
emergency engines they are subject to management standards (oil and filter change
and inspect air cleaners, hoses and belts). The source is required to comply with these
requirements by May 3, 2013. The appropriate applicable requirements will be included
in the renewal permit.
Compliance Assurance Monitoring (CAM) Applicability
CAM was reviewed for these units during the first renewal (issued January 1, 2006). At
that time it was determined that CAM did not apply to these units, since the Title V
permit specified a continuous monitoring method for NOx (per 40 CFR Part 64 §
64.2(b)(1)(vi)). Since there have been no physical changes to the existing emissions
units and no new units added since the first renewal, there is no change to the CAM
applicability at this facility.
Page 3
III. Discussion of Modifications Made
Source Requested Modifications
The source submitted their renewal application on August 10, 2009. In their renewal
application, the source did not request any changes to their permit.
Other Modifications
In addition to the modifications requested by the source, the Division has included
changes to make the permit more consistent with recently issued permits, include
comments made by EPA on other Operating Permits, as well as correct errors or
omissions identified during inspections and/or discrepancies identified during review of
this renewal.
The Division has made the following revisions, based on recent internal permit
processing decisions and EPA comments, to the Thermo E & P Renewal Operating
Permit with the source's requested modifications. These changes are as follows:
Page Following Cover Page
• The monitoring and compliance periods and report and certification due dates
are shown as examples. The appropriate monitoring and compliance periods
and report and certification due dates will be filled in after permit issuance and
will be based on permit issuance date. Note that the source may request to keep
the same monitoring and compliance periods and report and certification due
dates as were provided in the original permit. However, it should be noted that
with this option, depending on the permit issuance date, the first monitoring
period and compliance period may be short (i.e. less than 6 months and less
than 1 year).
Section I — General Activities and Summary
• Revised the language in Condition 1.1 to address attainment status of the area in
which the facility is located and corrected the citation for the definition of 8-hr
ozone control area.
• Revised the language in Condition 1.4 to include Section IV, Condition 3.d and to
note that only part of Condition 3.g is state-only enforceable (last paragraph).
Note that Section IV, Condition 3.d (affirmative defense provisions for excess
emissions during malfunctions) is state-only until approved by EPA in the SIP.
• Condition 2 (alternative operating scenario for turbine replacement) was revised
to reflect current language and to clarify that only temporary turbine replacement
is allowed.
Page 4
• Made minor revisions to the language in Condition 3 (prevention of significant
deterioration) to be more consistent with other permits. In addition, revised this
condition to address the attainment status of the area in which the facility is
located.
• Added a column to the Table in Condition 6.1 for the startup date of the
equipment.
Section 11.1 - Turbines
• Based on EPA's response to a petition on another Title V operating permit, minor
language changes were made to various permit conditions (both in the table and
the text) to clarify that only natural gas is used as fuel for permit conditions that
rely on fuel restriction for the compliance demonstration.
• The performance test frequency in Condition 1.5.4 was revised to every five
years.
Section 11.2 — Portable Monitoring Requirements
• The portable monitoring language was updated to the most recent version.
Section 11.3 — Performance Test Requirements
• The performance test frequency was revised to every five years. In addition, the
language was revised to specify that the performance test fulfills the quarterly
portable monitoring requirement for that period.
"New" Section 11.5 — Emergency Compression Ignition Engines
There are two engines included in the insignificant activity list that are considered
insignificant under either the provisions in Colorado Regulation No. 3, Part C, Sections
II.E.3.nnn (emergency generators) or xxx (stationary internal combustion engines).
However, under the "catch-all" provisions in Regulation No. 3, Part C, Section II.E,
sources that are subject to any federal or state applicable requirement, such as National
Emission Standards for Hazardous Air Pollutants (NESHAPs), may not be considered
insignificant activities. EPA promulgated National Emission Standards for Hazardous
Air Pollutants for Reciprocating Internal Combustion Engines on March 3, 2010 which
apply to these engines; therefore, they can no longer be considered insignificant
activities. Although the units cannot be considered insignificant activities, since the
Division has not adopted either the January 18, 2008 or March 3, 2010 revisions to the
RICE MACT, both of which address area sources, the engines are still exempt from
APEN reporting and minor source construction permit requirements.
Engine descriptions are as follows:
Page 5
Fire Pump Engine: Cummings, Model No. V-504-F2, Serial No. 3161293, rated at
187 hp, with a heat input rate of 1.7 mmBtu/hr.
Emergency Generator: Detroit Diesel, Model No. V7163-7300, Serial No.
20247994, rated at 745 hp, with a heat input rate of 6.7 mmBtu/hr.
The appropriate applicable requirements for these engines are as follows:
• Except as provided for below, visible emissions shall not exceed 20% opacity
(Reg 1, Section II.A.1)
• Visible emissions shall not exceed 30% opacity, for a period or periods
aggregating more than six (6) minutes in any sixty (60) minute period, during fire
building, cleaning of fire boxes, soot blowing, start-up, process modifications, or
adjustment or occasional cleaning of control equipment, when burning coal (Reg
1, Section II.A.4)
Based on engineering judgment, the Division believes that the operational
activities of fire building, cleaning of fire boxes and soot blowing do not apply to
diesel engines. In addition, since these engines are not equipped with control
equipment the operational activities of adjustment or occasional cleaning of
control equipment also do not apply to the engines. Finally, based on
engineering judgment, it is unlikely that process modifications will occur with
these emergency engines. Therefore, for these units the 30% opacity provision
only applies during startup.
• SO2 emission shall not exceed 0.8 lbs/mmBtu (Reg 1, Section VI.B.4.b.(i)).
• 40 CFR Part 63 Subpart ZZZZ requirements — management practices (oil and
filter change, inspect air cleaner and inspect hoses and belts)
• 40 CFR Part 63 Subpart A requirements
Since these engines are not subject to any emission limitations, monitoring
requirements, notification and reporting requirements the requirements in §§
63.7. 63.8, 63.9 and 63.10 do not apply. In addition, since these emission units
are existing the requirement in § 63.5 (preconstruction review and notification
requirements) do not apply. Finally, Table 8 of Subpart ZZZZ indicates that
operation and maintenance requirements in 63.6(e) do not apply. Therefore, the
permit will only include the prohibition and circumvention requirements in § 63.4.
Since these units are not subject to APEN reporting or minor source construction permit
requirements, the permit will not include any requirements for calculating emissions.
In their September 8, 2010 comments on the draft permit, the source requested that the
requirements in 40 CFR Part 63 Subpart ZZZZ that were included in the draft permit be
streamlined to clarify the substantive requirements. The Division typically includes the
requirements from federal regulations as they appear in the regulation and so the
Page 6
Division cannot make the requested changes. However, the Division has included a
simplified list of the substantive requirements for these engines in Appendix H of the
permit.
Section IV— General Conditions
• Added a version date to the General Conditions.
• The upset requirements in the Common Provisions Regulation (general condition
3.d) were revised December 15, 2006 (effective March 7, 2007) and the revisions
were included in the permit. Note that these provisions are state-only
enforceable until approved by EPA into Colorado's state implementation plan
(SIP).
• Removed the statement in Condition 3.g (affirmative defense provisions)
addressing EPA approval and state-only applicability. The EPA has approved
the affirmative defense provisions, with one exception and the exception, which
is state-only enforceable is identified in Section I, Condition 1.4.
• Replaced the reference to "upset" in Condition 5 (emergency provisions) and 21
(prompt deviation reporting) with "malfunction".
• The title for Condition 6 was changed from "Emission Standards for Asbestos" to
"Emission Controls for Asbestos" and in the text the phrase "emission standards
for asbestos" was changed to "asbestos control".
• General Condition No. 21 (prompt deviation reporting) was revised to include the
definition of prompt in 40 CFR Part 71.
• Replaced the phrase "enhanced monitoring" with "compliance assurance
monitoring" in General Condition No. 22.d.
• Labeled the 3`d paragraph of General Condition 29.a as 29.b and added the
provisions in Reg 7, Section III.C as paragraph e.
Appendices
• As discussed previously, the standby diesel generator and the diesel fire pump
were removed from the insignificant activity list in Appendix A and are included in
Section II of the permit.
• Appendix B and C were replaced with revised Appendices.
• Changed the mailing address for EPA in Appendix D.
• Added Appendix H (simplified list of 40 CFR Pad 63 Subpart ZZZZ requirements)
Page 7
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Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Thermo Power & Electric LLC
First Issued: January 1 , 1999
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Thermo Power& OPERATING PERMIT NUMBER
Electric LLC
FACILITY ID: 1230126 95OPWE001
RENEWED:
EXPIRATION DATE:
MODIFICATIONS: See Appendix F of Permit
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
sec. and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATION:
Thermo Power and Electric LLC. 510 18th Street
510 18`h Street Greeley, Colorado 80631
Greeley, CO 80631 Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received: August 10, 2009
And Additional Information Received: September 8, 2010
Nature of Business: Cogeneration of Electricity and Steam
Primary SIC: 4931
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Richard Recor Name: Richard Recor
Title: General Manager Title: General Manager
Phone: (970) 352-6700 Phone: (970) 352-6700
SUBMITTAL DEADLINES
Semi-Annual Monitoring Period: EXAMPLE (January 1 - June 30, July 1 —December 31)
Semi-Annual Monitoring Report: EXAMPLE (Due on Aug. 1, 2006 & Feb. 1, 2007 & subsequent years)
Annual Compliance Period: EXAMPLE (Begins January 1 to December 31)
Annual Compliance Certification: EXAMPLE (Due on February 1, 2007 and subsequent years)
Note that the Semi-Annual Monitoring Reports and Annual Compliance Certifications must be received
at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the
purposes of determining the timely receipt of those reports/certifications.
TABLE OF CONTENTS:
SECTION I - General Activities and Summary I
1. Permitted Activities 1
2. Alternative Operating Scenarios (8/23/06 version) 2
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant
Deterioration (PSD) 4
4. Accidental Release Prevention Program (112(r)) 5
5. Compliance Assurance Monitoring (CAM) 5
6. Summary of Emission Units 5
SECTION II - Specific Permit Terms 6
1. S001/S002 - Two (2) GE LM5000 Natural Gas Fired Turbines (339 MMBtu/hr each) 6
2. Portable Monitoring Requirements (6/1/06 version) 13
3. Performance Test Requirements 14
4. Continuous Parametric Monitoring and Compliance Algorithm Requirements 14
5. M001 - Diesel Fuel Fired Internal Combustion Engines 17
SECTION III - Permit Shield 23
1. Specific Non-Applicable Requirements Z3
2. General Conditions 23
3. Streamlined Conditions 24
SECTION IV- General Permit Conditions 25
1. Administrative Changes 25
2. Certification Requirements 25
3. Common Provisions 25
4. Compliance Requirements 29
5. Emergency Provisions 30
6. Emission Controls for Asbestos 30
7. Emissions Trading, Marketable Permits, Economic Incentives 30
8. Fee Payment 30
9. Fugitive Particulate Emissions 31
10. Inspection and Entry 31
11. Minor Permit Modifications 31
12. New Source Review 31
13. No Property Rights Conveyed 31
14. Odor 31
15. Off-Permit Changes to the Source 32
16. Opacity 32
17. Open Burning 32
18. Ozone Depleting Compounds 32
19. Permit Expiration and Renewal 32
20. Portable Sources 32
21. Prompt Deviation Reporting 32
22. Record Keeping and Reporting Requirements 33
23. Reopenings for Cause 34
24. Section 502(6)(10) Changes 34
25. Severability Clause 35
26. Significant Permit Modifications 35
TABLE OF CONTENTS:
27. Special Provisions Concerning the Acid Rain Program 35
28. Transfer or Assignment of Ownership 35
29. Volatile Organic Compounds 35
30. Wood Stoves and Wood burning Appliances 36
APPENDIX A - Inspection Information 1
Directions to Plant: 1
Safety Equipment Required. 1
Facility Plot Plan: 1
List of Insignificant Activities 1
APPENDIX B 1
Reporting Requirements and Definitions 1
Monitoring and Permit Deviation Report - Part I 5
Monitoring and Permit Deviation Report - Part II 7
Monitoring and Permit Deviation Report - Part III 9
APPENDIX C 1
Format for Annual Compliance Certification Reports 1
APPENDIX D 1
Notification Addresses 1
APPENDIX E 1
Permit Acronyms 1
APPENDIX F 1
Permit Modifications 1
APPENDIX G 1
Algorithm for NOx & CO Compliance Verification 1
APPENDIX H 1
Simplified Version of the Substantive Requirements in Section II, Condition 5.1 1
•
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 1
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 This facility consists of a cogeneration facility defined under Standard Industrial Classification
4931. Electricity for sale is produced by two (2) combustion turbines and a steam turbine. Each
combustion turbine serves a generator rated at 42.5 MW (name-plate) and the steam turbine
generator is rated at 16.3 MW (name-plate). In addition to the combustion turbines, significant
emission units at this facility consist of one (1) diesel-fired engine driving an emergency
generator and one (1) diesel-fired engine driving an emergency fire water pump.
This facility is located in an area classified as attainment/maintenance for carbon monoxide
(CO). Under that classification, all SIP-approved requirements for CO will continue to apply in
order to prevent backsliding under the provisions of Section 1100) of the Federal Clean Air Act.
This Area is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
Wyoming, an affected state is within 50 miles of the plant. Rocky Mountain National Park, a
Federal Class I designated area is within 100 kilometers of the plant.
1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 This Operating Permit incorporates the applicable requirements contained in the underlying
construction permits, and does not affect those applicable requirements, except as modified
during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements of Part B. Any revisions made using
the provisions of Regulation No. 3, Part C shall become new applicable requirements for
purposes of this operating permit and shall survive reissuance. This permit incorporates the
applicable requirements (except as noted in Section II) from the following construction permits:
87WE113-1 and 87WE113-2.
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado
Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State-only enforceable conditions are: Permit Condition Number(s):
Section II, Condition 1.12.3 (opacity) and Section IV - Conditions 3.d, 3.g (last paragraph), 14
and 18 (as noted)
1.5 All information gathered pursuant to the requirements of this permit is subject to the
Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions
in Section IV of this permit. Either electronic or hard copy records are acceptable.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 2
2. Alternative Operating Scenarios (8/23/06 version)
The following Alternative Operating Scenario (AOS) for temporary and permanent combustion turbine
replacement and turbine component replacement has been reviewed in accordance with the requirements
of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, and
Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source
New Source Review and Prevention of Significant Deterioration and has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any combustion turbine replacement performed in accordance with this AOS,
and the permittee shall be allowed to perform such turbine or turbine component replacement without
applying for a revision to this permit or obtaining a new Construction Permit.
2.1 Routine Turbine Component Replacements
2.1.1 The following physical or operational changes to the turbines in this permit are not
considered a modification for purposes of NSPS GG,NSR/PSD, or Regulation No. 3:
2.1.1.1 Replacement of stator blades, turbine nozzles, turbine buckets, fuel
nozzles, combustion chambers, seals, and shaft packings, provided that
they are of the same design as the original.
2.1.1.2 Changes in the type or grade of fuel used, if the original gas turbine
installation, fuel nozzles, etc. were designed for its use.
2.1.1.3 An increase in the hours of operation (unless limited by a permit
condition).
2.1.1.4 Variations in operating loads within the turbine design specification.
2.1.1.5 Any physical change constituting routine maintenance, repair or
replacement.
2.1.2 Turbines undergoing any of the above changes are subject to all federally applicable
and state-only requirements set forth in this permit (including monitoring and record
keeping), and shall be subject to any shield afforded by this permit. If replacement of
any of the components listed in Conditions 2.1.1.1 or 2.1.1.5 above results in a
change in serial number for the turbine, a letter explaining the action as well as a
revised APEN and appropriate filing fee shall be submitted to the Division within 30
days of the replacement.
2.1.3 Note that the repair or replacement must be genuinely the same design. Except in
accordance with the Alternative Operating Scenario set forth below, the Division does
not consider that this allows for the entire replacement (or reconstruction) of an
existing turbine with an identical new one or one similar in design or function.
Rather, the Division considers the repair or replacements to encompass the repair or
replacement of components at a turbine with the same (or functionally similar)
components.
Operating Permit Number: 95OPWE00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 3
2.2 Turbine Replacement
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary replacement turbine. "Temporary" is defined as in the same service for 270 operating
days or less in any 12 month period. The 270 days is the total number of days that the turbine is
in operation. If the turbine operates only part of a day, that day counts towards the 270 day total.
Note that the compliance demonstrations made as part of this AOS are in addition to any
compliance demonstrations required by this permit.
All replacement turbines are subject to all federally applicable and state-only requirements set
forth in this permit (including monitoring and record keeping), and shall be subject to any shield
afforded by this permit.
Results of all tests and the associated calculations pursuant required by this AOS shall be
submitted to the Division within 30 calendar days of the test. Results of all tests shall be kept on
site for five (5) years and made available to the Division upon request.
The permittee shall maintain a log on-site to contemporaneously record the start and stop date of
any turbine replacement, the manufacturer, model number, horsepower, and serial number of the
turbine(s) that are replaced during the term of this permit, and the manufacturer, model number,
horsepower, and serial number of the replacement turbine.
2.2.1 The permittee may temporarily replace an existing permitted turbine provided such
replacement turbines are General Electric, Model No. LM5000 combustion turbines
without modifying this permit, so long as the emissions from the temporary
replacement turbine comply with the emission limitations for the existing permitted
turbine as determined in Section 2.3. Measurement of emissions from the temporary
replacement turbine shall be made as set forth in Section 2.3.
The permittee may temporarily replace a grandfathered turbine or a turbine that is
not subject to emission limits without modifying this permit. In this circumstance,
potential annual emissions of NO„ and CO from the temporary replacement turbine
must be less than or equal to the potential annual emissions of NO, and CO from the
original grandfathered turbine or for the turbine that is not subject to emission limits,
as determined by applying appropriate emission factors (e.g. AP-42 or manufacturer's
emission factors)
2.3 Portable Analyzer Testing
The permittee shall measure nitrogen oxide (NO,) and carbon monoxide (CO) emissions in the
exhaust from the replacement turbine using a portable flue gas analyzer within seven (7)
operating days of commencing operation of the replacement engine.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit •
Permit # 95OPWE001 Page 4
All portable analyzer testing required by this permit shall be conducted using the Division's
Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's
website at: http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual or short term emission limit, the results of the tests shall be
converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year
(whichever applies) in order to monitor compliance. If a source is not limited in its hours of
operation the test results will be multiplied by the maximum number of hours in the month or
year (8760), whichever applies.
If the portable analyzer results indicate compliance with both the NOx and CO emission
limitations, in the absence of credible evidence to the contrary, the source may certify that the
turbine is in compliance with both the NOx and CO emission limitations for the relevant time
period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the
contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or
CO emission limitations, the turbine will be considered to be out of compliance from the date of
the portable analyzer test until a portable analyzer test indicates compliance with both the NOx
and CO emission limitations or until the turbine is taken offline.
2.4 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the
installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is
therefore essentially an advanced construction permit review. The AOS cannot be used for
additional new emission points for any site; a turbine that is being installed as an entirely new
emission point and not as part of an AOS-approved replacement of an existing onsite turbine
must go through the appropriate Construction/Operating permitting process prior to installation.
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD)
3.1 This facility is categorized as a PSD major stationary source (potential to emit of NOx > 100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
(see Colorado Regulation No. 3, Part D, Sections II.A.26 and 42) or a modification which is
major by itself(Potential to Emit> 100 tons/year) for any pollutant listed in Colorado Regulation
3, Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may
result in the application of the PSD review requirements.
3.2 This source is categorized as a NANSR major stationary source (Potential to Emit of NOx >100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
(see Regulation No. 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which
is major by itself (Potential to Emit > 100 tons/year of either VOC or NOx) may result in the
application of the NANSR review requirements.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 5
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of NANSR and PSD review regulations.
4. Accidental Release Prevention Program (112(r))
4.1 Based on the information provided by the applicant, this facility is not subject to the provisions
of the Accidental Release Prevention Program (section 112(r) of the Federal Clean Air Act).
5. Compliance Assurance Monitoring (CAM)
5.1 The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre-control emissions that
exceed or are equivalent to the major source threshold. They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV:
The turbines are not subject to CAM since at the time the CAM plan was required the Title V
permit specified a continuous compliance determination method (40 CFR Part 64 §
64.2(b)(1)(vi), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Emission AIRS Facility Description Startup Date Pollution
Unit Stack Identifier Control Device
Number Number
S001 001 T001 General Electric LM5000 Natural Gas Combustion 1988 Steam Injection
Turbine, Rated at 339 MMBtu/hr. Serial No. 474- for NOx
203.
S002 002 T002 General Electric LM5000 Natural Gas Combustion 1988 Steam Injection
Turbine, Rated at 339 MMBtu/hr. Serial No. 474- for NOx
122.
M001 N/A M001 One (1)Cummins, Model No. V-504-F2, Serial No. Emergency fire Uncontrolled
20247994, diesel-fired engine driving an emergency water pump
fire water pump engine, rated at 187 hp and 1.7 engine
mmBtu/hr. manufactured
One(1) Detroit Diesel, Model No. V7163-7300, 1987
Serial No. 3161293,diesel-fired engine driving an Emergency
emergency generator, rated at 745 hp and 6.7 generator engine
mmBtu/hr. manufactured
1980
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 6
SECTION II - Specific Permit Terms
1. S001/S002 - Two (2) GE LM5000 Natural Gas Fired Turbines (339 MMBtu/hr each)
(Limits are for each turbine)
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
BACT 1.1 N/A N/A N/A See Condition 1.1.
Requirements
RACT 1.2. N/A N/A N/A See Condition 1.2.
Requirements
PM 1.3. N/A 20.8 tons/yr 0.0066 lb/MMBtu Recordkeeping Monthly
and Calculation
0.11 lb/MMBtu N/A Fuel Restriction Only Natural
Gas is Used as
Fuel.
PM10 N/A N/A 0.0066 lb/MMBtu Recordkeeping Anually
VOC N/A 6.24 tons/yr 0.0021 lb/MMBtu and Calculation Monthly
SO2 1.4. 2.28 lbs/hr 10.0 tons/yr 0.0067 lb/MMBtu Recordkeeping Monthly
and Calculation
0.35 lb/MMBtu N/A Fuel Restriction See Condition
1.4.
NOx 1.5. N/A 535.5 tons/yr N/A Continuous Continuously
Parametric
Monitoring
System and
Compliance
Algorithm
100 ppmvd @15%oxygen at ISO Recordkeeping Monthly
conditions, on a 1-hr average and Calculation
CO 1.6. 10,27 lbs/hr 45.0 tons/yr 0.030 lb/MMBtu Portable Quarterly
Monitoring
Performance Test Every Five(5)
Years
Natural Gas 1.7 N/A 2,970 N/A Fuel Invoices Monthly
Consumption MMscf/yr
Continuous 1.8 T-44 (low pressure turbine N/A Continuous Continuously
Parametric temperature),To(ambient Sensors, Meters
Monitoring temperature), Steam Injection and Recorder
System and Rate,and Fuel Use
Compliance
Algorithm
Fuel Sulfur 1.9 Not to Exceed 2.36 grains/100 scf N/A See Condition 1.9.
Content
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 7
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
Btu Content of 1.10. N/A N/A N/A Fuel Invoices Monthly
Natural Gas
NSPS 1.11 N/A N/A N/A As Required by Subject to
General NSPS General NSPS General
Provisions
Provisions Provisions
Opacity 1.12 Not to Exceed 20%, Except as N/A See Condition 1.12.
Provided for Below
For Certain Operational
Activities -Not to Exceed 30%,
for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
State-Only Requirement: Not
to Exceed 20%
1.1 The combustion turbines are subject to the requirements of the Prevention of Significant
Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for
control of Nitrogen Oxides (NOx). BACT for NOx has been determined to be steam injection
with the emission limit identified in Condition 1.5.2 (Colorado Construction Permit 87WE113-1
and—2).
1.2 The combustion turbines are subject to the Reasonably Available Control Technology
Requirements (RACT) for PM and CO emissions (Colorado Regulation No. 3, Part B, Section
III.D.2.a). RACT has been determined as follows:
1.2.1 RACT for CO has been determined to be good combustion practices with the short-
term (hourly) emission limit included in Condition 1.6. The turbines and associated
control equipment shall be operated and maintained in accordance with
manufacturer's requirements and good engineering practices. Such procedures and
preventative maintenance schedules shall be maintained and made available to the
Division upon request.
1.2.2 RACT for PM has been determined to be the use of natural gas as fuel. In the
absence of credible evidence to the contrary, compliance with the PM RACT
requirements is presumed provided the gas used as fuel meets the requirements in
Condition 1.9.
1.3 Particulate Matter (PM and PMio) and VOC emissions are subject to the following requirements:
1.3.1 PM and VOC emissions from each turbine shall not exceed the annual limitations
stated above (Colorado Construction Permits 87WE113-1 and -2 as modified under
the provisions of Section I, Condition 1.3 to remove the short term (lbs/hr) limits).
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 8
Monthly emissions from each turbine shall be calculated by the end of the subsequent
month using the above emission factors (from AP-42, Section 3.1, April 2000, Table
3.1-2a), the monthly natural gas consumption and the higher heating value of the gas
(see Condition 1.10) in the following equation:
tons/month=(EF,lbs/MMBtu)x(Natural Gas Use,MMSCF/mo)X(Heat Content of Fuel,MMBtu/MMSCF)
2000 lbs/ton
Monthly emissions from each turbine shall be used in a twelve-month rolling total
to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
1.3.2 Particulate Matter (PM) emissions from each turbine shall not exceed 0.11
lb/MMbtu (Colorado Regulation No. 1, Section III.A.1). In the absence of credible
evidence to the contrary, compliance with the particulate matter emission limits is
presumed since only natural gas is permitted to be used as fuel in the turbines.
The numeric PM standards were determined using the design heat input for each
turbine (339 mmBtu/hr) in the following equation:
PE = 0.5 x (FI)-°'2°' where: PE = particulate standard in lbs/mmBtu
FI = fuel input in mmBtu/hr
1.3.3 Annual emissions of PMIo from each turbine, for the purposes of APEN reporting and
payment of fess shall calculated using the above emissions factors, the annual natural
gas consumption and the higher heating value of the fuel (see Condition 1.10) in the
following equation:
tons/year=(EF, Ibs/MMBtu)x(Natural Gas Use, MMSCF/year)X(Heat Content of Fuel,MMBtu/MMSCF)
2000 lbs/ton
1.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
1.4.1 Sulfur Dioxide emissions from each turbine shall not exceed the above limitations
(Colorado Construction Permits 87WE113-1 and -2).
1.4.1.1 In the absence of credible evidence to the contrary compliance with the
short-term (hourly) emission limit shall be presumed provided the natural
gas used as fuel meets the sulfur limit in Condition 1.9.
1.4.1.2 Compliance with annual emission limitations shall be monitored as
follows:
a. Monthly emissions from each turbine shall be calculated by the end
of the subsequent month using the emission factor (based on permitted
hourly emission limit divided by design rate of turbine (339
mmBtu/hr)), the monthly natural gas consumption and the higher
heating value of the fuel (see Condition 1.10) in the equation provided
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 9
in Condition 1.3.1. Monthly emissions from each turbine shall be
used in a twelve-month rolling total to monitor compliance with the
annual limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
b. The natural gas used as fuel shall meet the sulfur limit in Condition
1.9.
1.4.2 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 0.35
lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section
VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary,
compliance with the SO2 limitations is presumed provided the natural gas used as fuel
meets the sulfur content requirement in Condition 1.9.
1.5 Nitrogen Oxide (NOx) emissions shall not exceed the following:
1.5.1 Nitrogen Oxide Emissions from each turbine shall not exceed the above limitations
(Colorado Construction Permits 87WE113-1 and -2, as modified under the provisions
of Section I, Condition 1.3 to remove the hourly limitation). Compliance with the
annual limitation shall be monitored using the continuous parametric monitoring
system and compliance algorithm specified in Condition 1.8. Hourly emissions
predicted by the algorithm from each turbine shall be summed to determine monthly
emissions by the end of the subsequent month. Monthly emissions shall be used in a
rolling twelve-month rolling total to monitor compliance with the annual limitation.
Each month a new twelve month total shall be calculated using the previous twelve
months data.
1.5.2 For BACT purposes, Nitrogen Oxide Emissions from each turbine shall not exceed
100 ppmvd at 15% O2 corrected to ISO Conditions, on a 1-hr average (Colorado
Construction Permits 87WE113-1 and -2). The continuous parametric monitoring
system and compliance algorithm specified in Condition 1.8 shall be used to monitor
compliance with the BACT NOx emission limit. Any hours that exceed the limitation
shall be reported on the excess emission report required by Condition 4.3.
1.5.3 Portable monitoring shall be conducted quarterly in accordance with the requirements
in Condition 2 to monitor compliance with the NOx limits in Conditions 1.5.1 and
1.5.2. The performance testing conducted to satisfy the requirements in Condition
1.5.4 shall also satisfy the requirement to conduct portable monitoring for that
quarterly period.
1.5.4 A performance test shall be conducted every five (5) years in accordance with the
requirements in Condition 3 to monitor compliance with the NOx limits in Conditions
1.5.1 and 1.5.2.
Note that the previous performance tests for these units were conducted on April 23,
2008.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 10
1.6 Carbon Monoxide (CO) emissions from each turbine shall not exceed the above limitations
(Colorado Construction Permits 87WE113-1 and -2). Compliance with the emission limitations
shall be monitored as follows:
1.6.1 The continuous parametric monitoring system and compliance algorithm specified in
Condition 1.8 shall be used to monitor compliance with the short-term (hourly) CO
emission limit. Any hours that exceed the limitation shall be reported on the excess
emission report required by Condition 4.3.
1.6.2 The emission factor listed above (based on permitted hourly emission limit divided by
design rate of turbine (339 mmBtu/hr)) shall be used to calculate emissions.
Monthly emissions shall be calculated by the end of the subsequent month using the
above emission factor, the monthly natural gas consumption and the higher heating
value of the gas (see Condition 1.10) in the equation provided in Condition 1.3.1.
Monthly emissions from each turbine shall be used in a twelve-month rolling total
to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
If a reference method test is conducted under the provisions of Condition 1.6.3, and
the results of the testing show that either the NOx or CO emission rates/factors are
greater than the emission rates/factors listed above, the permittee shall apply for a
modification to this permit to reflect, at a minimum, the higher emission rates/factors
within 60 days of the completion of the reference method test.
1.6.3 Portable Monitoring shall be conducted quarterly in accordance with the provisions in
Condition 2 of this permit. The performance testing conducted to satisfy the
requirements in Condition 1.6.4 shall also satisfy the requirement to conduct portable
monitoring for that quarterly period.
1.6.4 A performance test shall be conducted in accordance with the provisions in Condition
3 of this permit.
1.7 Natural gas consumption for each turbine shall not exceed the limitations stated above
(Colorado Construction Permits 87WE113-1 and -2). Natural gas use for each turbine shall be
measured and recorded using the continuous parametric monitoring system specified in
Condition 1.8. Monthly natural gas consumption, as determined by fuel invoices, shall be used
in a twelve-month rolling total to monitor compliance with the annual limitations. Each month a
new twelve month total shall be calculated using the previous twelve months data.
1.8 A continuous parametric monitoring system and compliance algorithm shall be installed and
operated on each turbine to measure and record the following:
1.8.1 Low pressure turbine temperature (T-44), hourly average;
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 11
1.8.2 Ambient temperature(To), hourly average;
1.8.3 Steam injection rate, hourly average;
1.8.4 Fuel use, hourly average;
1.8.5 Compliance check for NOx and CO emissions, for each hour of operation; and
1.8.6 NOx emissions, lbs/hr
The continuous parametric monitoring system and compliance algorithm shall meet the
requirements in Condition 4 of this permit.
1.9 The fuel gas sulfur content shall not exceed the limitation stated above (Construction Permits
87WE113-1 and -2, as modified under the provisions of Section I, Condition 1.3 to reflect the
fuel sulfur content that the SO2 emission limits are based on). The following methods may be
used to demonstrate that the fuel gas sulfur requirement is met:
1.9.1 The demonstration shall be made using the gas quality characteristics in a current,
valid purchase contract, tariff sheet or transportation contract for the gaseous fuel; or
1.9.2 Representative fuel sampling data provided number and frequency of sampling data
meets the requirements of either sections 2.3.1.4 or 2.3.2.4 of Appendix D of 40 CFR
Part 75.
1.10 The Btu content of the natural gas used to fuel these turbines shall be determined monthly from
supplier supplied fuel invoices. Calculation of emissions as specified in Conditions 1.3.1,
1.4.1.2.a and 1.6.2 shall be based on the most recent fuel invoice. Calculation of annual
emissions as specified in Condition 1.3.3 shall be based on the average Btu content for the year.
The Btu content used in emission calculations shall be based on the lowest gross heating value of
the fuel.
1.11 Regulation No. 6, Part A, Subpart A, General Provisions applies as follows:
1.11.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere (40 CFR Part 60 Subpart A §
60.12).
1.11.2 At all times, including periods of startup, shutdown, and malfunction owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 12
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source (Colorado Construction Permits 113-1 and -2
and 40 CFR Subpart A § 60.11(d)).
1.12 The turbines are subject to the following opacity requirements:
1.12.1 Except as provided for in Condition 1.12.2 below, no owner or operator of a source
shall allow or cause the emission into the atmosphere of any air pollutant which is in
excess of 20% opacity (Colorado Construction Permits 87WE113-1 and —2 and
Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to each
turbine.
1.12.2 No owner or operator of a source shall allow or cause to be emitted into the
atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire
boxes, soot blowing, start-up, process modifications, or adjustment or occasional
cleaning of control equipment which is in excess of 30% opacity for a period or
periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each
turbine.
1.12.3 State-Only Requirement: No owner or operator may discharge, or cause the
discharge into the atmosphere of any particulate matter which is greater than 20%
opacity (Colorado Regulation No. 6, Part B, Section II.C.3). This opacity standard
applies to each turbine.
This opacity standard applies at all times except during periods of startup, shutdown
and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in
Colorado Regulation No. 6, Part B, Section I.A).
Note that this opacity requirement is more stringent than the opacity requirement in
Condition 1.12.2 during periods of building of a new fire, cleaning of fire boxes, soot
blowing, process modifications and adjustment or occasional cleaning of control
equipment.
In the absence of evidence to the contrary, compliance with the above opacity requirements shall
be presumed since only natural gas is permitted to be used as fuel for these turbines.
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 13
2. Portable Monitoring Requirements (6/1/06 version)
Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted
quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly
tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable
monitoring requirements do not apply.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at:
http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For
comparison with an annual or short term emission limit, the results of the tests shall be converted to a
lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in
order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year (8760), whichever applies.
If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in
the absence of credible evidence to the contrary, the source may certify that the engine is in compliance
with both the NOx and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations
or until the engine is taken offline.
For comparison with the emission rates/factors, the emission rates/factors determined by the portable
analyzer tests and approved by the Division shall be converted to the same units as the emission
rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission
rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent
testing results to the contrary (as approved by the Division), the permittee shall apply for a modification
to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion
of the test.
Results of all tests conducted shall be kept on site and made available to the Division upon request.
Operating Permit Number: 95OPWE00l First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 14
3. Performance Test Requirements
Performance testing shall be performed every five (5) years to monitor compliance with the NOx and
CO emission limitations in Conditions 1.5.1, 1.5.2 and 1.6. Performance testing shall be conducted in
accordance with the provisions of 40 CFR Part 60 Subpart GG § 60.335 for NOx and Method 10 (40
CFR Part 60 Appendix A) for CO or other test methods or procedures acceptable to the Division.
Note that the previous performance tests for these units were conducted on April 23, 2008.
A stack testing protocol shall be submitted for Division approval at least thirty (30) calendar days prior
to any performance of the test required under this condition. No stack test required herein shall be
performed without prior written approval of the protocol by the Division. The Division reserves the
right to witness the test. In order to facilitate the Division's ability to make plans to witness the test,
notice of the date(s) for the stack test shall be submitted to the Division at least thirty (30) calendar days
prior to the test. The Division may for good cause shown, waive this thirty (30) day notice requirement.
In instances when a scheduling conflict is presented, the Division shall immediately contact the
permittee in order to explore the possibility of making modifications to the stack test schedule. The
required number of copies of the compliance test results shall be submitted to the Division within forty-
five (45) calendar days of the completion of the test unless a longer period is approved by the Division.
4. Continuous Parametric Monitoring and Compliance Algorithm Requirements
4.1 Equipment and QA/QC Requirements
4.1.1 The monitoring and recording devices specified in Conditions 1.8.1 through 1.8.4
shall be accurate to within + 5 % and approved by the Division (Colorado
Construction Permits 87WE113-1 and-2).
4.1.2 The monitoring and recording devices shall be operated, maintained and calibrated in
accordance with manufacturer's requirements. Such procedures and preventative
maintenance schedules shall be maintained and made available to the Division upon
request.
4.1.3 All continuous monitoring systems and monitoring devices shall be installed such that
representative measurements of process parameters are obtained (40 CFR Part 60
Subpart A § 60.13(O).
4.1.4 A NOx and CO algorithm quality assurance/quality control plan shall be developed to
assess continued accuracy of the algorithm. Such plan shall be made available to the
Division upon request. Revisions to the plan shall be made to the plan at the request
of the Division.
4.2 General Provisions
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 15
4.2.1 The permittee shall ensure that all continuous emission monitoring systems required
are in operation and monitoring unit emissions or opacity at all times except for
monitoring system breakdowns, repairs and calibration checks (40 CFR Part 60
Subpart A § 60.13(e)).
4.2.2 Alternative monitoring systems, alternative reference methods, or any other
alternatives for the required continuous monitoring systems shall not be used without
having obtained prior written approval from the appropriate agency, either Division
or the U.S. EPA, depending on which agency is authorized to approve such
alternative under applicable law. Any alternative continuous emission monitoring
systems or continuous opacity monitoring systems must be certified in accordance
with the requirements of 40 CFR Part 60 prior to use.
4.2.3 All test and monitoring equipment, methods, procedures and reporting shall be
subject to the review and approval by the appropriate agency, either the Division or
the U.S. EPA, depending on which agency is authorized to approve such items under
applicable law, prior to any official use. The Division shall have the right to inspect
such equipment, methods and procedures and data obtained at any time. The
Division may provide a witness(s) for any and all tests as Division resources permit.
4.2.4 A file suitable for inspection shall be maintained of all measurements, including
continuous monitoring system, monitoring device, and performance testing
measurements; all continuous monitoring system performance evaluations; all
continuous monitoring system or monitoring device calibration checks; adjustments
and maintenance performed on these systems or devices; and all other information
required by applicable portions of 40 CFR Part 60 Subpart A (40 CFR Part 60
Subpart A § 60.7(f), as adopted by reference in Colorado Regulation No. 6, Part A).
4.2.5 Records shall be maintained of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the source; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or
monitoring device is inoperative (40 CFR Part 60 Subpart A § 60.7(b)).
4.3 Recordkeeping and Reporting Requirements
4.3.1 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each calendar quarter, a report of excess
emissions for all pollutants monitored for that quarter (40 CFR Part 60 Subpart A §
60.7(c)). This report shall consist of the following information and/or reporting
requirements as specified by the Division:
4.3.1.1 The magnitude of excess emissions computed in accordance with 40 CFR
Part 60 Subpart A § 60.13(h), any conversion factor(s) used, and the date
and time of commencement and completion of each time period of excess
emissions and the process operating time during the reporting period (40
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 16
CFR Part 60 Subpart A § 60.7(c)(1)).
4.3.1.2 Specific identification of each period of excess emissions that occurs
during startups, shutdowns, and malfunctions of the affected facility. The
nature and cause of any malfunction (if known), the corrective action
taken or preventative measures adopted (40 CFR Part 60 Subpart A §
60.7(c)(2)).
4.3.1.3 The date and time identifying each period during which the continuous
monitoring system was inoperative except for zero and span checks and
the nature of the system repairs or adjustments (40 CFR Part 60 Subpart A
§ 60.7(c)(3)).
4.3.1.4 When no excess emissions have occurred or the continuous monitoring
system(s) have not been inoperative, repaired, or adjusted, such
information shall be stated in the report (40 CFR Part 60 Subpart A §
60.7(c)(4)).
4.3.2 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each calendar quarter, a summary report for that
quarter (40 CFR Part 60 Subpart A § 60.7(c)). One summary report form shall be
submitted for each pollutant monitored. This report shall contain the information and
be presented in a format approved by the Division.
If the total duration of excess emissions for the reporting period is less than 1 percent
of the total operating time for the reporting period and continuous monitoring system
(CMS) downtime is less than 5 percent of the total operating time for the reporting
period, only the summary report form shall be submitted and the excess emission
report described in Condition 4.3.1 need not be submitted unless required by the
Division (40 CFR Part 60 Subpart A § 60.7(d)(1)).
If the total duration of excess emissions for the reporting period is 1 percent or greater
of the total operating time for the reporting period or the total CMS.downtime for the
reporting period is 5 percent or greater of the total operating time for the reporting
period, the summary report form and the excess emission report described in
Condition 4.3.1 shall both be submitted (40 CFR Part 60 Subpart A § 60.7(d)(1)).
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 17
5. M001 - Diesel Fuel Fired Internal Combustion Engines
Emergency Fire Pump (187 hp) & Emergency Generator (745 hp)
Unless otherwise specified, the requirements apply to each engine
Parameter Permit Limitations Compliance Monitoring
Condition Emission Factor
Number Short Term Long Term Method Interval
MACT ZZZZ 5.1. Change Oil and Filter N/A See Condition 5.1.
Requirements Inspect Air Cleaner
Inspect all Hoses and Belts
SO2 5.2. 0.8 lbs/mmBtu N/A Fuel Restriction Only Diesel
Fuel is Used
as Fuel
Opacity 5.3 Not to Exceed 20%Except as N/A EPA Method 9 See Condition
Provided for Below 5.3
For Startup—Not to Exceed
30%, for a Period or Periods
Aggregating More than Six (6)
Minutes in any 60 Consecutive
Minutes
MACT General 5.4. N/A N/A N/A See Condition 5.4
Provisions
Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction
permit requirements in Regulation No. 3, Part B.
5.1 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National
Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines", as follows:
These requirements included in this Condition 5.1 are only federally enforceable. As of the date
of revised permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart ZZZZ
promulgated on March 3, 2010 have not been adopted into Colorado Regulation No. 8, Part E by
the Division and are therefore not state-enforceable. In the event that the Division adopts these
requirements these engines will be subject to the APEN reporting and minor source permitting
requirements and these requirements will be state-enforceable.
Note that for information purposes a simplified list of the substantive applicable requirements in
40 CFR Part 63 Subpart ZZZZ for these engines is included in Appendix H of this permit.
When do I have to comply with this subpart (§ 60.6595)
5.1.1 If you have an existing stationary CI RICE located at an area source of HAP
emissions, you must comply with the applicable emission limitations and operating
limitations no later than May 3, 2013. (§ 63.6595(a)(1))
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 18
What emission limitations and operating limitations must I meet if I own or operate an existing
CI RICE located at an area source of HAP emissions (¢ 63.6603)
5.1.2 If you own or operate an existing stationary CI RICE located at an area source of
HAP emissions, you must comply with the requirements in Table 2d to this subpart
and the operating limitations in Table 2b to this subpart which apply to you. (§
63.6603(a)) The requirements in Table 2d that apply to these emergency CI RICE are
as follows:
5.1.2.1 Change oil and filter every 500 hours of operation or annually whichever
comes first. (Table 2d, item 4.a)
5.1.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever
comes first. (Table 2d, item 4.b)
5.1.2.3 Inspect all hoses and belts every 500 hours of operation or annually
whichever comes first, and replace as necessary. (Table 2d, item 4.c)
Notwithstanding the above requirements, the following applies:
5.1.2.4 Sources have the option to utilize an oil analysis program as described in
Condition 5.1.8 in order to extend the specified oil change requirement in
Condition 5.1.2.1. (Table 2d, footnote 1)
5.1.2.5 If an emergency engine is operating during an emergency and it is not
possible to shut down the engine in order to perform the management
practice requirements on the schedule required in Conditions 5.1.2.1
through 5.1.2.3, or if performing the management practice on the required
schedule would otherwise pose an unacceptable risk under Federal, State,
or local law, the management practice can be delayed until the emergency
is over or the unacceptable risk under Federal, State, or local law has
abated. The management practice should be performed as soon as
practicable after the emergency has ended or the unacceptable risk under
Federal, State, or local law has abated. Sources must report any failure to
perform the management practice on the schedule required and the
Federal, State or local law under which the risk was deemed unacceptable.
(Table 2d, footnote 2)
What are my general requirements for complying with this subpart? 63.6605)
5.1.3 You must be in compliance with the emission limitations and operating limitations in
this subpart that apply to you at all times. (§ 63.6605(a))
5.1.4 At all times you must operate and maintain any affected source, including associated
air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions. The
general duty to minimize emissions does not require you to make any further efforts
to reduce emissions if levels required by this standard have been achieved.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 19
Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Division which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source. (§
63.6605(b))
What are my monitoring, installation, collection, operation, and maintenance requirements? (§
63.6625)
5.1.5 If you own or operate an existing stationary RICE with a site rating of less than 100
brake HP located at a major source of HAP emissions, an existing stationary
emergency RICE, or an existing stationary RICE located at an area source of HAP
emissions not subject to any numerical emission standards shown in Table 2d to this
subpart, you must operate and maintain the stationary RICE and after-treatment
control device (if any) according to the manufacturer's emission-related written
instructions or develop your own maintenance plan which must provide to the extent
practicable for the maintenance and operation of the engine in a manner consistent
with good air pollution control practice for minimizing emissions. (§ 63.6625(e))
5.1.6 If you own or operate an existing emergency stationary RICE with a site rating of less
than or equal to 500 brake HP located at a major source of HAP emissions or an
existing emergency stationary RICE located at an area source of HAP emissions, you
must install a non-resettable hour meter if one is not already installed. (§ 63.6625(f))
5.1.7 If you operate a new or existing stationary engine, you must minimize the engine's
time spent at idle during startup and minimize the engine's startup time to a period
needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after
which time the emission standards applicable to all times other than startup in Tables
la, 2a, 2c, and 2d to this subpart apply. (§ 63.6625(h))
5.1.8 If you own or operate a stationary engine that is subject to the work, operation or
management practices in Condition 5.1.2.1, you have the option of utilizing an oil
analysis program in order to extend the specified oil change requirement in Condition
5.1.2.1. The oil analysis must be performed at the same frequency specified for
changing the oil in Condition 5.1.2.1. The analysis program must at a minimum
analyze the following three parameters: Total Base Number, viscosity, and percent
water content. The condemning limits for these parameters are as follows: Total Base
Number is less than 30 percent of the Total Base Number of the oil when new;
viscosity of the oil has changed by more than 20 percent from the viscosity of the oil
when new; or percent water content (by volume) is greater than 0.5. If all of these
condemning limits are not exceeded, the engine owner or operator is not required to
change the oil. If any of the limits are exceeded, the engine owner or operator must
change the oil before continuing to use the engine. The owner or operator must keep
records of the parameters that are analyzed as part of the program, the results of the
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE00I Page 20
analysis, and the oil changes for the engine. The analysis program must be part of the
maintenance plan for the engine. (§ 63.6625(i))
How do I demonstrate continuous compliance with the emission limitations and operating
limitations? (§ 63.6640)
5.1.9 If you own or operate an existing emergency stationary RICE with a site rating of less
than or equal to 500 brake HP located at a major source of HAP emissions, a new
emergency stationary RICE with a site rating of more than 500 brake HP located at a
major source of HAP emissions that was installed on or after June 12, 2006, or an
existing emergency stationary RICE located at an area source of HAP emissions, you
must operate the engine according to the conditions described below. (§ 63.6640(f))
5.1.9.1 For owners and operators of emergency engines, any operation other than
emergency operation, maintenance and testing, and operation in non-
emergency situations for 50 hours per year, as permitted in this section, is
prohibited. (§ 63.6640(f)(1))
5.1.9.2 There is no time limit on the use of emergency stationary RICE in
emergency situations. (§ 63.6640(0(2))
5.1.9.3 You may operate your emergency stationary RICE for the purpose of
maintenance checks and readiness testing, provided that the tests are
recommended by Federal, State or local government, the manufacturer, the
vendor, or the insurance company associated with the engine.
Maintenance checks and readiness testing of such units is limited to 100
hours per year. The owner or operator may petition the Administrator for
approval of additional hours to be used for maintenance checks and
readiness testing, but a petition is not required if the owner or operator
maintains records indicating that Federal, State, or local standards require
maintenance and testing of emergency RICE beyond 100 hours per year.
(§ 63.6640(f)(3))
5.1.9.4 You may operate your emergency stationary RICE up to 50 hours per year
in non-emergency situations, but those 50 hours are counted towards the
100 hours per year provided for maintenance and testing. The 50 hours per
year for non-emergency situations cannot be used for peak shaving or to
generate income for a facility to supply power to an electric grid or
otherwise supply power as part of a financial arrangement with another
entity; except that owners and operators may operate the emergency
engine for a maximum of 15 hours per year as part of a demand response
program if the regional transmission organization or equivalent balancing
authority and transmission operator has determined there are emergency
conditions that could lead to a potential electrical blackout, such as
unusually low frequency, equipment overload, capacity or energy
deficiency, or unacceptable voltage level. The engine may not be operated
for more than 30 minutes prior to the time when the emergency condition
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 21
is expected to occur, and the engine operation must be terminated
immediately after the facility is notified that the emergency condition is no
longer imminent. The 15 hours per year of demand response operation are
counted as part of the 50 hours of operation per year provided for non-
emergency situations. The supply of emergency power to another entity or
entities pursuant to financial arrangement is not limited by this Condition
5.1.9.4, as long as the power provided by the financial arrangement is
limited to emergency power. (§ 63.6640(O(4))
What records must I keep? (§ 63.6655)
5.1.10 You must keep records of the maintenance conducted on the stationary RICE in order
to demonstrate that you operated and maintained the stationary RICE and after-
treatment control device (if any) according to your own maintenance plan if you own
or operate an existing stationary CI RICE located at an area source of HAP emissions
subject to management practices as shown in Conditions 5.1.2.1 through 5.1.2.3. (§
63.6655(e) and § 63.6655(e)(3))
5.1.11 If you own or operate an existing emergency stationary CI RICE located at an area
source of HAP emissions that does not meet the standards applicable to non-
emergency engines, you must keep records of the hours of operation of the engine
that is recorded through the non-resettable hour meter. The owner or operator must
document how many hours are spent for emergency operation, including what
classified the operation as emergency and how many hours are spent for non-
emergency operation. If the engines are used for demand response operation, the
owner or operator must keep records of the notification of the emergency situation,
and the time the engine was operated as part of demand response. (§ 63.6655(f) and §
63.6655(O(2))
5.2 Sulfur Dioxide (SO2) emissions shall not exceed 0.8 lbs/mmBtu (Colorado Regulation No. 1,
Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the
SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in
these engines.
5.3 Opacity of emissions from the engine shall not exceed the following:
5.3.1 Except as provided for in Condition 5.3.2 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess of
20% opacity (Colorado Regulation No. 1, Section II.A.1).
5.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere
any air pollutant resulting from startup which is in excess of 30% opacity for a period or
periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4).
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 22
Compliance with these limitations shall be monitored by conducting opacity observations in
accordance with EPA Reference Method 9 as follows:
5.3.3 An engine startup period of less than 60 minutes shall not require a startup opacity
observation. If the engine startup period is greater than 60 minutes, one opacity
observation shall be made for each consecutive 4 hour period of startup during daylight
hours. In addition, a record shall be kept of the date and time the engine started and when
it was shutdown.
5.3.4 Continued operation of the engine after the completion of the startup period shall require
monthly opacity observations. If the startup and operation of the engine lasts less than a
total of 4 hours from engine start to engine stop, in any one day no opacity observations
are required for that day.
5.3.5 If no opacity observations are made pursuant to Conditions 5.3.3 and 5.3.4 above, then an
opacity observation shall be conducted annually.
5.3.6 All opacity observations shall be performed by an observer with current and valid
Method 9 certification. Results of Method 9 readings and a copy of the certified Method
9 reader's certificate shall be kept on site and made available to the Division upon
request.
5.4 These engines are subject to the requirements in 40 CFR part 63 Subpart A "General
Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified
in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to
the following:
5.4.1 Prohibited activities in § 63.4(a).
5.4.2 Circumvention in § 63.4(b)
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 23
SECTION III - Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D., & XIII.B and § 25-7-114.4(3)(a), C.R.S.
1. Specific Non-Applicable Requirements
Based on the information available to the Division and supplied by the applicant, the following parameters and
requirements have been specifically identified as non-applicable to the facility to which this permit has been
issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit
issuance. In addition, this shield does not protect the source from any violations that occur as a result of any
modification or reconstruction on which construction commenced prior to permit issuance.
Emission Unit Non-Applicable Requirement Justification
Description&
Number
S003 Colorado Regulation 1, III.A- Particulate The Cooling Tower at this facility does not fall under the
Emissions regulated categories for particulate emissions.
S001/S002 Colorado Regulation No. I, IV. Gaseous fuel is the only fuel burned in these turbines.
S001/S002 40 CFR Part 64, as adopted by reference in These units are exempt from CAM under 40 CFR Part 64 §
Colorado Regulation No. 3, Part C, Section 64.2(b)(1)(vi), as adopted by reference in Colorado Regulation
XIV. No. 3,Part C, Section XIV because at the time the CAM plan
was required the Title V permit specified a continuous
compliance determination method.
All Colorado Regulation No. 6, Part B, IV. - Emission Units at this facility do not fall under the regulated
Performance Standards for New Sources of categories for this requirement.
Sulfur Dioxide
S003 40 CFR 63, Subpart Q Cooling Tower This facility does not use chromium-based water treatment
(Colorado Regulation No. 8, Part A, chemicals.
NESHAPs, Subpart Q)
All 40 CFR 72, Federal Acid Rain Permitting The facility is exempted from the acid rain regulations by 40
Provisions (Colorado Regulation No. 18) CFR 72.6(b)(5). The facility is a qualifying facility that entered
into a power purchase agreement for more than 15%of its total
capacity prior to November 15, 1990.
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning
enforcement in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time of permit issuance;
Operating Permit Number: 95OPWE00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 24
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the
federal act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to
§ 25-7-111(2)0), C.R.S., or the ability of the Administrator to obtain information pursuant to §
114 of the federal act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause
pursuant to Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source
subsequent to permit issuance.
3. Streamlined Conditions
The following applicable requirements have been subsumed within this operating permit using the pertinent
streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the
listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed
requirements. •
Permit Condition I Streamlined(Subsumed)Requirements
Section 14 Condition Regulation No. 6, Part B, Section 11.D.3.b [sulfur dioxide standard]-State-only
1.4.2. Requirement
Section II,Condition 40 CFR Part 60 Subpart GG § 60.332(b)(as adopted by reference in Regulation No. 6, Part
1.5.2 A, Subpart GG) [Nitrogen Oxide emissions shall not exceed 115 ppmvd at 15%oxygen and
ISO standard day conditions]
Section II,Condition 1.8. 40 CFR Part 60 Subpart GG § 60.334(a), as adopted by reference in Colorado Regulation
No. 6,Part A [continuous monitoring system to measure and record the fuel consumption
rate and ratio of water to fuel]
Section II,Condition 1.8 40 CFR Part 60 Subpart GG § 60.334(])(1)(iii),as adopted by reference in Colorado
Regulation No. 6, Part A [NOx excess emission reporting]
Section II,Condition 1.9 40 CFR Part 60 Subpart GG §60.333 (as adopted by reference in Colorado Regulation No.
6, Part A [SO2 standards— 150 ppmvd or 0.8 weight percent sulfur in fuel]
Section II,Condition 1.9 40 CFR Part 60 Subpart GG §60.334(h)(3), as adopted by reference in Colorado Regulation
No. 6, Part A [source shall monitor the sulfur content of the fuel]
Section IV, Conditions 40 CFR Part 60 Subpart Dc § 60.48c(i), as adopted by reference in Colorado Regulation 6,
21.6&c Part A [retain records for two(2)years]
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
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SECTION IV - General Permit Conditions
3/13/10 version
Administrative Changes
Regulation No. 3, 5 CCR 1001-5, Part A, § III.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes
that are described in Regulation No. 3, Part A, § 1.B.1. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.9., V.C.16.a.& e. and V.C.I7.
a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the
truth, accuracy and completeness of such form, report or certification stating that, based on information and belief
formed after reasonable inquiry,the statements and information in the document are true, accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s)used for determining the compliance status of the source, currently and over the reporting
period; and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act,the
permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation, 5 CCR 1001-2 §§ II.A., JIB., ll.C., II .E., ILF., II.I,and II.J
a. To Control Emissions Leaving Colorado
When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause
the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving
State.
Operating Permit Number: 95OP W E001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
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b. Emission Monitoring Requirements
The Division may require owners or operators of stationary air pollution sources to install,maintain, and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s)
and furnish the Division a written report of the results of such test(s)in order to determine compliance with
applicable emission control regulations.
Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves, in specific cases,the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance; or
(iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes, Title 25,Article 7,and pursuant to regulations
promulgated by the Commission.
Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility. The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s). Operations during period of
startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s)unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as
follows:
(i) Sampling ports adequate for testmethods applicable to such facility;
(ii) Safe sampling platform(s);
(iii) Safe access to sampling platform(s); and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be
conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining
compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply. In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined
using the arithmetic mean of the results of the two other runs.
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Colorado Operating Permit
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Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted.
d. Affirmative Defense Provision for Excess Emissions during Malfunctions
Note that until such time as the U.S. EPA approves this provision into the Colorado State Implementation Plan
(SIP), it shall be enforceable only by the State.
An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil
penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be
relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility
must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that:
(i) The excess emissions were caused by a sudden,unavoidable breakdown of equipment, or a sudden,
unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of
the owner or operator;
(ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and
avoided,or planned for, and could not have been avoided by better operation and maintenance practices;
(iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being
exceeded;
(iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum
extent practicable during periods of such emissions;
(v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or
maintenance;
(ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator, and shall not constitute an additional applicable requirement; and
(x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality
standards established in the Commissions' Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits, including, but not limited to, new source performance standards and national emission standards
for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip)
limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but
not necessarily limited to, certain limits with 30-day or longer averaging times, limits that indicate they apply during
malfunctions, and limits that indicate they apply at all times or without exception.
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Colorado Operating Permit
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e. Circumvention Clause
A person shall not build,erect, install, or use any article, machine, equipment, condition, or any contrivance, the use
of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals
an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
f. Compliance Certifications
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation
Plan shall preclude the use, including the exclusive use,of any credible evidence or information,relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement, the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or
maintenance;
(iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment),then the
bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence;and,
(viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator, and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible, but no later than two(2)hours after the start of the next working day, and shall
submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Colorado Operating Permit
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The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants, or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-
four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration(PSD) increments.
In making any determination whether a source established an affirmative defense,the Division shall consider the
information within the notification required above and any other information the Division deems necessary, which
may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No. 3, 5 CCR 1001-5,Part C, §§ III.C.9., V.C.I I. & 16.d. and §25-7-122.1(2),C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and
Regulation No. 3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the
state act and Regulation No. 3,shall be enforceable pursuant to state law, and shall not be enforceable by citizens
under § 304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either
statute is grounds for enforcement action, for permit termination,revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination,revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified,revoked,reopened, and reissued, or terminated for cause. The filing of any request by
the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned
changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of
Regulation No. 3, Part C.
d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the
Division, any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the Division copies of records required to be kept by the permittee, including
information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental, and shall not sanction noncompliance with,the applicable requirements on
which it is based.
f For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance,the permittee shall submit, at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division, progress reports which contain the following:
(I) dates for achieving the activities, milestones,or compliance required in the schedule for compliance, and
dates when such activities, milestones, or compliance were achieved; and
(ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any
preventive or corrective measures adopted.
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
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g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No. 3, 5 CCR 1001-5,Part C, § VII
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission
limitation if the permittee demonstrates, through properly signed,contemporaneous operating logs, or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards, or other requirements in the permit;and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency,and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency, any steps taken to mitigate emissions,and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8, 5 CCR 1001-10, Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8, Part B," asbestos control."
7. Emissions Trading, Marketable Permits, Economic Incentives
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.13.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S. §§ 25-7-114.1(6)and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the
date of invoice, unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
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c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. 1, 5 CCR 1001-3, § 1II.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. I, § III.D.I.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division,or any authorized representative, to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is
conducted,or where records must be kept under the terms of the permit;
b. have access to,and copy,at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment(including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
11. Minor Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & Xl.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, Part B
The permittee shall not commence construction or modification of a source required to be reviewed under the New Source •
Review provisions of Regulation No. 3, Part B, without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.I l.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No. 2, 5 CCR 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
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15. Off-Permit Changes to the Source
Regulation No. 3, 5 CCR 1001-5, Part C, $ XII.B.
The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an
applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including
any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit . The permit shield shall not apply to any off-permit change.
16. Opacity
Regulation No. 1,5 CCR 1001-3, §§ I., II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. I, §§ I.-II.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-17
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., II.C., lID., Ill., IV., V. of Regulation No. I5 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No. 3, 5 CCR 1001-5, Part C, §§ 111.B.6., IV.C., V.C.2.
a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months, prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No.3,5 CCR 1001-5, Part C, § II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in
location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b.
The permitter shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
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Colorado Operating Permit
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"Prompt" is defined as follows:
a. Any definition of"prompt" or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit; or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of
deviations will be submitted based on the following schedule:
(i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements,the report shall be made within 24
hours of the occurrence;
(ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements,the report shall be made within 48
hours; and
(iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below.
c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone
(303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification
by telephone or facsimile must specify that this notification is a deviation report for an Operating Permit.] A
written notice, certified consistent with General Condition 2.a. above(Certification Requirements), shall be
submitted within 10 working days of the occurrence, All deviations reported under this section shall also be
identified in the 6-month report required above.
"Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of
avoiding enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No. 3, 5 CCR 1001-5, Part A, § II.; Part C, §§ V.C.6., V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain
compliance monitoring records that include the following information:
(i) date,place as defined in the Operating Permit, and time of sampling or measurements;
(ii) date(s)on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis; and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5)years from the date of the monitoring sample, measurement,report or application. Support information, for this
purpose, includes all calibration and maintenance records and all original strip-chart recordings for continuous
monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12)month period,as well as compliance certifications for the past five (5)years on-site at all times. A permittee
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Colorado Operating Permit
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shall make available for the Air Pollution Control Division's review all other records of required monitoring data
and support information required to be retained by the permittee upon 48 hours advance notice by the Division.
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every
six(6)months, unless an applicable requirement,the compliance assurance monitoring rule, or the Division requires
submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly
identified in such reports.
e. The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing, modifying, or altering
any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted,
unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised
APEN shall be filed annually whenever a significant change in emissions,as defined in Regulation No. 3, Part A, '
I1.C.2., occurs; whenever there is a change in owner or operator of any facility,process, or activity; whenever new
control equipment is installed; whenever a different type of control equipment replaces an existing type of control
equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required,the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No. 3,5 CCR 1001-5, Part C, & XIII.
a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III.,except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years, unless the effective date of the requirements is later than
the date on which the permit expires, or unless a general permit is obtained to address the new requirements;
whenever additional requirements(including excess emissions requirements)become applicable to an affected
source under the acid rain program;whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Section 502(b)(10) Changes
Regulation No. 3, 5 CCR 1001-5, Part C, § XII.A.
The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of
each such notice given to its Operating Permit.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit # 95OPWE001 Page 35
25. Severability Clause
Regulation No. 3,5 CCR 1001-5, Part C, § V.C.10.
In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring,
record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable.
26. Significant Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C § 11I.B.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to
use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.I.b. & 8
a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Pan 72, both provisions shall
be incorporated into the permit and shall be federally enforceable.
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the
regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited.
28. Transfer or Assignment of Ownership
Regulation No. 3, 5 CCR 1001-5, Part C, § II.C.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
29. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, §§ III &V.
a. For sources located in an ozone non-attainment area or the Denver Metro Attainment Maintenance Area, all storage
tank gauging devices, anti-rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and
pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened,
actuated, or used for necessary and proper activities(e.g. maintenance). Such opening, actuation,or use shall be
limited so as to minimize vapor loss.
Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Testing shall be conducted as in Regulation No. 7, Section VIII.C.3.
b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids,
transferred to any tank, container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit# 95OPWE001 Page 36
transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom.
c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology(RACT)is utilized.
d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant, or gasoline dispensing facility as defined in
Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers,stored
in open containers, or disposed of in any other manner that would result in evaporation.
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b,
above.
30. Wood Stoves and Wood burning Appliances
Regulation No. 4, 5 CCR 1001-6
The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use
of wood stoves and wood burning appliances.
Operating Permit Number: 95OP WE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Appendices
OPERATING PERMIT APPENDICES
A - INSPECTION INFORMATION
B - MONITORING AND PERMIT DEVIATION REPORT
C - COMPLIANCE CERTIFICATION REPORT
D - NOTIFICATION ADDRESSES
E - PERMIT ACRONYMS
F - PERMIT MODIFICATIONS
G - ALGORITHM FOR NOX & CO COMPLIANCE VERIFICATION
H - SIMPLIFIED VERSION OF THE SUBSTANTIVE
REQUIREMENTS IN SECTION II, CONDITION 5.1
*DISCLAIMER:
None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as otherwise provided in the permit and is presented to
assist the source, permitting authority, inspectors, and citizens.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 1
APPENDIX A - Inspection Information
Directions to Plant:
The plant is adjacent to the northwest corner of UNC Campus, next to active railroad tracks and just
north of existing UNC Steam Plant in Greeley.
Safety Equipment Required:
None Listed
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on September 29, 1994 with the source's
Title V Operating Permit Application.
List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the understanding of
the facility layout. Since there is no requirement to update such a list, activities may have changed since
the last filing.
Insignificant activities and/or sources of emissions as submitted in the application are as follows:
Diesel forklift
Diesel storage tank, for generator
Diesel storage tank, for fire pump
Five (5) indoor chemical storage tanks
Sodium Hypochlorite storage tank
Three (3) oil lubrication system vents, for Turbine #1
Three (3) oil lubrication system vents, for Turbine #2
Oil lubrication system vent, for steam turbine
Cooling Tower (S003)
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 2
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32
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 1
APPENDIX B
Reporting Requirements and Definitions
with codes ver 2/20/07
Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly:
(A) makes any false material statement, representation, or certification in, or omits material information
from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report,
plan, or other document required pursuant to the Act to be either filed or maintained (whether with
respect to the requirements imposed by the Administrator or by a State);
(B) fails to notify or report as required under the Act; or
(C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to
be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title
18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of
any person under this paragraph is for a violation committed after a first conviction of such person under
this paragraph, the maximum punishment shall be doubled with respect to both the fine and
imprisonment.
The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes
- a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits.
All required reports must be certified by a responsible official.
Report#1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six
months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements
must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by data from
any monitoring protocol, or by any other monitoring which is required by the permit as well as the
recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate
monitoring, fuel analyses, and operational or control device parameter monitoring.
Report#2: Permit Deviation Report (must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from permit
requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of
Operating Permit Number: 95OPWE00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 2
such deviations, and any corrective actions or preventive measures taken. All deviations from any term or
condition of the permit are required to be summarized or referenced in the annual compliance certification.
For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions.
Additional discussion on these conditions is provided later in this Appendix.
For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set
forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or
otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For
example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes
of this operating permit are any of the following:
(1) A situation where emissions exceed an emission limitation or standard contained in the permit;
(2) A situation where process or control device parameter values demonstrate that an emission limitation
or standard contained in the permit has not been met;
(3) A situation in which observations or data collected demonstrates noncompliance with an emission
limitation or standard or any work practice or operating condition required by the permit; or,
(4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance
Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM)
For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation
Report. All deviations shall be reported using the following codes:
1 = Standard: When the requirement is an emission limit or standard
2 = Process: When the requirement is a production/process limit
3= Monitor: When the requirement is monitoring
4 =Test: When the requirement is testing
5 =Maintenance: When required maintenance is not performed
6 = Record: When the requirement is recordkeeping
7 = Report: When the requirement is reporting
8= CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
9=Other: When the deviation is not covered by any of the above categories
Report#3: Compliance Certification (annually, as defined in the permit)
Submission of compliance certifications with terms and conditions in the permit, including emission limitations,
standards, or work practices, is required not less than annually.
Compliance Certifications are intended to state the compliance status of each requirement of the permit over the
certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 3
permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other
material information (i.e. information beyond required monitoring that has been specifically assessed in relation
to how the information potentially affects compliance status), that information must be identified and addressed
in the compliance certification. The compliance certification must include the following:
• The identification of each term or condition of the permit that is the basis of the certification;
• Whether or not the method(s) used by the owner or operator for determining the compliance
status with each permit term and condition during the certification period was the method(s)
specified in the permit. Such methods and other means shall include, at a minimum, the methods
and means required in the permit. If necessary, the owner or operator also shall identify any
other material information that must be included in the certification to comply with section
113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or
omitting material information;
• The status of compliance with the terms and conditions of the permit, and whether compliance
was continuous or intermittent. The certification shall identify each deviation and take it into
account in the compliance certification. Note that not all deviations are considered violations.'
• Such other facts as the Division may require, consistent with the applicable requirements to
which the source is subject, to determine the compliance status of the source.
The Certification shall also identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance
Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM)
Note the requirement that the certification shall identify each deviation and take it into account in the
compliance certification. Previously submitted deviation reports, including the deviation report submitted at the
time of the annual certification, may be referenced in the compliance certification.
Startup, Shutdown, Malfunctions and Emergencies
Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important
in both the deviation reports and the annual compliance certifications.
Startup, Shutdown, and Malfunctions
Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable
Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be
considered to be non-compliance since emission limits or standards often do not apply unless specifically stated
in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
' For example, given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes
an exception and/or special circumstances relating to that same event.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 4
confident of the information related to those deviations when making compliance determinations since they are
subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available
Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources.
Emergency Provisions
Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense
against enforcement action if they are properly reported.
DEFINITIONS
Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution
control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are
caused in part by poor maintenance or careless operation are not malfunctions.
Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process
equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily
caused by poor maintenance, careless operation, or any other preventable upset condition or preventable
equipment breakdown shall not be considered malfunctions.
Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of
the source, including acts of God, which situation requires immediate corrective action to restore normal
operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to
unavoidable increases in emissions attributable to the emergency. An emergency shall not include
noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance,
careless or improper operation, or operator error.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 5
Monitoring and Permit Deviation Report - Part I
1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the
Division as set forth in General Condition 21. The Table below must be completed for all equipment or
processes for which specific Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for describing
periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the
Table below. One Part II Form must be completed for each Deviation. Previously submitted reports
(e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety.
FACILITY NAME: Thermo Power and Electric, Inc.
OPERATING PERMIT NO: 95OPWE001
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations noted Deviation Malfunction/Emergency
During Period?' Code' Condition Reported
During Period?
Operating
Permit Unit ID Unit Description YES NO YES NO
S001 General Electric LM5000 Natural Gas
Combustion Turbine, Rated at 339 MMBtu/hr,
equipped with Steam Injection for NOx
control. Serial No. 474-203.
S002 General Electric LM5000 Natural Gas
Combustion Turbine,Rated at 339 MMBtu/hr,
equipped with Steam Injection for NOx
control. Serial No. 474-122.
M001 One(1)Cummins, Model No. V-504-F2, Serial
No.20247994,diesel-fired engine driving an
emergency fire water pump engine,rated at
187 hp and 1.7 mmBtu/hr.
One(1) Detroit Diesel, Model No. V7163-
7300, Serial No. 3161293,diesel-fired engine
driving an emergency generator, rated at 745
hp and 6.7 mmBtu/hr.
General Conditions
Insignificant Activities
See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred
shall be based on a reasonable inquiry using readily available information.
2Use the following entries as appropriate:
1 =Standard: When the requirement is an emission limit or standard
2 =Process: When the requirement is a production/process limit
3= Monitor: When the requirement is monitoring
4 =Test: When the requirement is testing
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 6
5=Maintenance: When required maintenance is not performed
6=Record: When the requirement is recordkeeping
7=Report: When the requirement is reporting
8=CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance
Monitoring(CAM)Rule)has occurred.
9=Other: When the deviation is not covered by any of the above categories
Operating Permit Number: 95OP W E00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 7
Monitoring and Permit Deviation Report- Part II
FACILITY NAME: Thermo Power and Electric, Inc.
OPERATING PERMIT NO: 95OPWE001
REPORTING PERIOD:
Is the deviation being claimed as an: Emergency Malfunction N/A
(For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration (start/stop date & time)
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Malfunctions/Emergencies Reported (if applicable)
Deviation Code Division Code QA:
SEE EXAMPLE ON THE NEXT PAGE
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 8
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Is the deviation being claimed as an: Emergency Malfunction XX N/A
(For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control - Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1730 4/10/06
END- 1800 4/10/06
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Malfunction/Emergencies Reported (if applicable)
5/30/06 to A. Einstein, APCD
Deviation Code Division Code QA:
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 9
Monitoring and Permit Deviation Report- Part III
REPORT CERTIFICATION
SOURCE NAME: Thermo Power and Electric, Inc.
FACILITY IDENTIFICATION NUMBER: 1230126
PERMIT NUMBER: 95OPWE001
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as
defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be
packaged with the documents being submitted.
STATEMENT OF COMPLETENESS
I have reviewed the information being submitted in its entirety and, based on information and belief
formed after reasonable inquiry, I certify that the statements and information contained in this submittal
are true, accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18-
1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is
guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7
122.1, C.R.S.
Printed or Typed Name Title
Signature of Responsible Official Date Signed
Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this
permit. No copies need be sent to the U.S. EPA.
Operating Permit Number: 95OPWE00l First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 1
APPENDIX C
Format for Annual Compliance Certification Reports
ver 2/20/07
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S.
EPA annually based on the effective date of the permit. The Table below must be completed for all equipment
or processes for which specific Operating Permit terms exist.
FACILITY NAME: Thermo Power and Electric, Inc.
OPERATING PERMIT NO: 95OPWE001
REPORTING PERIOD:
I. Facility Status
_ During the entire reporting period, this source was in compliance with ALL terms and conditions contained
in the Permit, each term and condition of which is identified and included by this reference. The method(s)
used to determine compliance is/are the method(s) specified in the Permit.
With the possible exception of the deviations identified in the table below, this source was in compliance
with all terms and conditions contained in the Permit, each term and condition of which is identified and
included by this reference, during the entire reporting period. The method used to determine compliance for
each term and condition is the method specified in the Permit, unless otherwise indicated and described in the
deviation report(s). Note that not all deviations are considered violations.
Operating Unit Description Deviations Monitoring Was Compliance Continuous
Permit Reported I Method per or Intermittent?3
Unit ID Permit?2
Previous Current YES NO Continuous Intermittent
S001 General Electric LM5000 Natural
Gas Combustion Turbine, Rated at
339 MMBtu/hr,equipped with Steam
Injection for NOX control. Serial No.
474-203.
S002 General Electric LM5000 Natural
Gas Combustion Turbine, Rated at
339 MMBtu/hr, equipped with Steam
Injection for NOX control. Serial No.
474-122.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 2
Operating Unit Description Deviations Monitoring Was Compliance Continuous
Permit Reported Method per or Intermittent?3
Unit ID Permit?2
Previous Current YES NO Continuous Intermittent
MOOT One(I)Cummins, Model No. V-
504-F2, Serial No.20247994,diesel-
fired engine driving an emergency
fire water pump engine,rated at 187
hp and 1.7 mmBtu/hr.
One(1)Detroit Diesel, Model No.
V7163-7300, Serial No. 3161293,
diesel-fired engine driving an
emergency generator,rated at 745 hp
and 6.7 mmBtu/hr.
General Conditions
Insignificant Activities°
If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current
deviation report (i.e. for the last six months of the annual reporting period), put an "X" under"current". Mark both columns if both
apply.
2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the
permit. If it was not,mark "no" and attach additional information/explanation.
Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent
Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance
has occurred.
NOTE:
The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the
absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance
for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its
permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not
indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then
the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time
period.
Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 3
II. Status for Accidental Release Prevention Program:
A. This facility is subject is not subject to the provisions of the Accidental
Release Prevention Program (Section 112(r) of the Federal Clean Air Act)
B. If subject: The facility is is not in compliance with all the
requirements of section 112(r).
1. A Risk Management Plan will be has been submitted to the
appropriate authority and/or the designated central location by the required date.
III. Certification
All information for the Annual Compliance Certification must be certified by a responsible official as defined in
Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with
the documents being submitted.
I have reviewed this certification in its entirety and, based on information and belief formed after
reasonable inquiry, I certify that the statements and information contained in this certification are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6),
C.R.S., makes any false material statement, representation, or certification in this document is guilty of a
misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S.
Printed or Typed Name Title
Signature Date Signed
NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit.
Operating Permit Number: 95OP W E001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix D
Notification Addresses Page 1
APPENDIX D
Notification Addresses
1. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Jim King
2. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF-T
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Permit Modifications, Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Air and Radiation Programs, 8P-AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 1
APPENDIX E
Permit Acronyms
Listed Alphabetically:
AIRS - Aerometric Information Retrieval System
AP-42 - EPA Document Compiling Air Pollutant Emission Factors
APEN - Air Pollution Emission Notice (State of Colorado)
APCD - Air Pollution Control Division (State of Colorado)
ASTM - American Society for Testing and Materials
BACT - Best Available Control Technology
BTU - British Thermal Unit
CAA - Clean Air Act (CAAA= Clean Air Act Amendments)
CCR - Colorado Code of Regulations
CEM - Continuous Emissions Monitor
CF - Cubic Feet (SCF = Standard Cubic Feet)
CFR - Code of Federal Regulations
CO - Carbon Monoxide
COM - Continuous Opacity Monitor
CRS - Colorado Revised Statute
EF - Emission Factor
EPA - Environmental Protection Agency
FI - Fuel Input Rate in Lbs/mmBtu
FR- Federal Register
G - Grams
Gal - Gallon
GPM - Gallons per Minute
HAPs - Hazardous Air Pollutants
HP - Horsepower
HP-HR - Horsepower Hour (G/HP-HR= Grams per Horsepower Hour)
LAER - Lowest Achievable Emission Rate
LBS - Pounds
M - Thousand
MM - Million
MMscf- Million Standard Cubic Feet
MMscfd - Million Standard Cubic Feet per Day
N/A or NA - Not Applicable
NOx - Nitrogen Oxides
NESHAP - National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards
P - Process Weight Rate in Tons/Hr
PE - Particulate Emissions
PM - Particulate Matter
PM,o - Particulate Matter Under 10 Microns
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 2
PPM Parts Per Million
PPMV Parts Per Million, by Volume
PPMVD Parts Per Million, by Volume, Dry
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
RACT - Reasonably Available Control Technology
SCC - Source Classification Code
SCF - Standard Cubic Feet
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
TPY - Tons Per Year
TSP - Total Suspended Particulate
VOC - Volatile Organic Compounds
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix F
Permit Modifications Page 1
APPENDIX F
Permit Modifications
DATE OF TYPE OF SECTION DESCRIPTION OF REVISION
REVISION MODIF ICA"PION NUMBER,
CONDITION
NUMBER
Operating Permit Number: 95OPWE00l First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix G
Algorithm for NOx and CO Compliance Verification Page 1
APPENDIX G
Algorithm for NOx & CO Compliance Verification
• GET STEAM I Ib/hrl
FUEL MOW1 T.. I'FI
To 1'F)
AS HOUR AVERAGES
•
CALCULATE 7.Tu • 100 . Tu/1410J
DO CO COMPLIANCE CHECK
NO ` To 2 40 •F 7 >YES
NO �To 2 20 'F 7 Y'5 YE�STEAM S 27,000 Sb/hr 7
♦ `
YES NO YES 7.. 2 92.5% 7> NO
C STEAM≤21,000 IC/hr 7
♦ ♦
YES„,.•
t 24.000 Ib/11r
♦ 4, i
CO EMISSION IS FLAG TF9S HOUR
IN COMPLIANCE AS EXCESS CO
EMISSION
DO NOx COMPLIANCE CHECK
r
CALCULATE NOx LBMR
0.1924 T44•0.2121 To•0.0023 Stm•177.0
CALCULATE NOx PPMV.
0.1591 744.0.2377 To•0.0021 Sim•113.9
V
•
YES / NOx LBMR 122.3 7 >NO
\ AND
NOx PPMV 5 100 7
•
NOx EMISSION FLAG THIS HOUR AS
IS IN COMPLIANCE I EXCESS NOx EMISSION
L 00000_1
FIGURE 7
E CHECK LOOP COMPLIANCE ALGORITHM FOR NOx&CO
COMPLIANCE VERIFICATION
Taken from• FlQoure 4-0 at Air Silences'October 1991 report THERMO POWER AND ELECTRIC
Permit Modlecatlon Report Sithe Energies U.SA,inc."
36 AIRSCIENCES INC.
tAI EwOCu COLORADO
Operating Permit Number: 95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
Simplified Version of the Substantive Requirements in Section II, Condition 5.1. Page 1
APPENDIX H
Simplified Version of the Substantive Requirements in Section II, Condition 5.1
The following list is intended to provide a simplified version of the substantive requirements in Section II,
Condition 5.1. Section II, Condition 5.1 of the permit includes the requirements applicable to existing
emergency compression ignition engines located at area sources in 40 CFR Part 63 Subpart ZZZZ. It should be
noted that compliance or non-compliance with the applicable requirements in 40 CFR Part 63 Subpart ZZZZ
shall be based on the language in the regulation, which has been included in Section II, Condition 5.1.
The following requirements take effect on May 3, 2013.
Work Practice Requirements:
(Section II, Condition 5.1.2 (§ 66.6603(a), Table 2d of Subpart ZZZZ))
• Change oil and filter every 500 hours of operation or annually whichever comes first.
• Inspect air cleaner every 1,000 hours of operation or annually whichever comes first.
• Inspect all hoses and belts every 500 hours of operation or annually whichever comes first, and replace
as necessary.
Note that in lieu of performing oil changes, an oil analysis program may be used— see Section II, Condition
5.1.8 (§ 63.6625).
Also note that if the engine is operating during an emergency and it is not possible to shut it down to
perform the required maintenance, is shall be performed as soon as practicable after the emergency has
ended (see Section II, Condition 5.1.2.5 (Subpart ZZZZ Table 2d footnote))
Operating and Monitoring Requirements
• Each engine shall be operated and maintained in accordance with manufacturer's instructions or source
developed maintenance plan. (Section II, Condition 5.1.5 (§ 63.6625(e))
• Each engine shall be equipped with a non-resettable hour meter. (Section II, Condition 5.1.6 (§
63.6625(f))
• Idling during startup shall not exceed 30 minutes. (Section II, Condition 5.1.7 (§ 63.6625(e))
Operating Restrictions
• There is no time limit on operation of the engine during an emergency. (Section II, Condition 5.1.9.2 (§
63.6640(f)(2))
• Operation of the engine during maintenance checks and readiness testing is limited to 100 hours per
year. (Section II, Condition 5.1.9.2 (§ 63.6640(f)(3))
Operating Permit Number: 95OP W E001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
Simplified Version of the Substantive Requirements in Section II, Condition 5.1. Page 2
• Operation of the engine during non-emergency periods is limited to 50 hours per year. The 50 hours per
year is counted towards the 100 hours per year allowed for maintenance checks and readiness testing.
The 50 hours for non-emergency operation is subject to the following limitations:
o Cannot be used for peak shaving or to generate income
o The engine can be operated for 15 hours per year as part of a demand response program if the
appropriate authorities have determined that there are emergency conditions that could lead to a
potential blackout. The 15 hours per year is counted towards the 50 hours per year of non-
emergency operation.
(Section II, Condition 5.1.9.4 (§ 63.6640(0(4))
Recordkeeping Requirements
• Retain maintenance records (Section II, Condition 5.1.10 (§ 63.6655(e) and (e)(3))
• Retain records of the hours of operation, as follows:
o How many hours spent on emergency operation, including what classified the operation as an
emergency
o How many hours spent on non-emergency operation
o If used for demand response, keep records of the notification of emergency situation and the time the
engine operated for demand response.
(Section II, Condition 5.1.11 (§ 63.6655(0 and (f)(2))
Operating Permit Number: 95OPWi 001 First Issued: 1/1/99
Renewed: DRAFT
STATE OF COLORADO
Bill Ritter,Jr., Governor
Martha E. Rudolph, Executive Director oe_,co7pP
Dedicated to protecting and improving the health and environment of the people of Colorado F-� �=p
4300 Cherry Creek Dr. S. Laboratory Services Division " ` � `
Denver,Colorado 80246-1530 8100 Lowry Blvd. 7x
Phone(303)692-2000 Denver,Colorado 80230-6928
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado of Public Health
http://www.cdphe.state.co.us and Environment
September 22, 2010
Mr. Richard Recor
General Manager
Thermo Power and Electric, LLC
510 18th Street
Greeley, CO 80631
REF: Thermo Power and Electric, LLC—Greeley Facility, FID# 1230126, OP# 95OPWE001
SUBJECT: Response to Comments on Draft Operating Permit
Dear Mr. Recor:
The Division received comments from your consultant on the draft Operating Permit(95OPWE001)and
Technical Review Document for the Greeley Facility on September 8, 2010 via e-mail. For the most part, the
comments primarily consist of a red-lined version of the draft permit. In general,the Division has incorporated
Thermo's comments as requested, with the following exceptions:
Item 1: Alternative Operating Scenario—Portable Analyzer Testing, Section I, Condition 2.3. Thermo
requested that the portable monitoring language be revised to specify that a subsequent portable
monitoring test was required within 14 days of the initial portable monitoring test that indicated
an exceedance of either the NOx or CO emission limitations.
Response: As a result of public comments received on another Title V permit and subsequent discussions
with EPA, the Division developed a protocol for portable monitoring so that the results of the
portable monitoring could be considered directly enforceable. Following this action, the Division
revised our portable monitoring language and the portable monitoring language contained in the
alternative operating scenarios for both turbine and engine replacement and has been including
the revised language in permits as they are revised. Since the Division considers that portable
monitoring results conducted in accordance with the Division's protocol are directly enforceable,
the requested change cannot be made.
Item 2: Section II, Condition 5.1. Thermo requested that the provisions in Section II, Condition 5.1 be
streamlined.
Response: For the most part, the language included in Section II, Condition 5.1 is directly from 40 CFR Part
63 Subpart ZZZZ and the Division cannot revise the language in these conditions. However, the
Division has included a simplified list of the substantive requirements in Appendix H of the
permit. Please be aware that the information in Appendix H is intended to provide a simplified
list of the requirements and that compliance and/or non-compliance with the requirements of 40
CFR Part 63 Subpart ZZZZ shall be based on the language in the regulation which has been
included in Section II, Condition 5.1 of the permit.
Mr. Richard Recor, Thermo Power and Electric, LLC September 22, 2010
Response to Comments on Draft Permit Page 2
The next step for this draft renewal permit will be to put it out for a 30-day Public Comment period. After that,
the proposed permit will go to EPA Region VIII for a 45-day review period. The regulations also require that the
applicant receive written notice of their right to a formal hearing before the Air Quality Control Commission at
the same time that the Public Comment packet goes out. You will receive a separate letter containing that
information.
We appreciate that you took the time to thoroughly review this draft. Please feel free to call me at(303) 692-3267
if you have any further questions.
Sincerely,
Jacqueline Joyce
Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
cc: Kevin Lewis, Air Sciences Inc.—via e-mail
(9/16/2010) Jackie Joyce - RE: Thermo Power and Electric Page 1 •
From: "Kevin Lewis" <klewis@airsci.com>
To: "'Jackie Joyce- <JEJOYCE@cdphe.state.co.us>
Date: 9/16/2010 2:43 PM
Subject: RE: Thermo Power and Electric
You are absolutely right:
1. Fire pump: Cummins, 1987, Model V-504-F2, 187 HP, Engine number
20247994, 1.7 MMBtu/hr
2. Emergency Generator: Detroit Diesel, 1980, Model V7163-7300, 745 HP,
S.N. 3161293, 6.7 MMBtu/hr
Kevin Lewis
720-389-4213 Office
303-638-2892 Mobile
303-484-5030 Fax
Air Sciences Inc.
1301 Washington Avenue, Suite 200
Golden, CO 80401-1915
Original Message
From: Jackie Joyce [mailto:JEJOYCE@cdphe.state.co.usj
Sent: Thursday, September 16, 2010 1:53 PM
To: Kevin Lewis
Subject RE: Thermo Power and Electric
Kevin,
I suspect that when you e-mailed comments to me on this facility you listed
the engine info in a table (or some other format) -well it didn't come out
as a table when I received it. I wanted to verify that I am listing the
engines correctly. Is the Cummins (187 hp), the emergency generator or is
it the Detroit Diesel (745 hp)? From my e-mail, it appeared that the
Cummins was the generator but I would have thought the emergency generator
was the larger engine and the water pump the smaller engine.
>>> "Kevin Lewis" <klewis@airsci.com> 9/15/2010 4:10 PM >>>
Still working on it.
Kevin Lewis
720-389-4213 Office
303-638-2892 Mobile
303-484-5030 Fax
Air Sciences Inc.
1301 Washington Avenue, Suite 200
Golden, CO 80401-1915
(9/16/2010) Jackie Joyce - RE: Thermo Power and Electric Page 2
Original Message
From: Jackie Joyce [mailto:JEJOYCE@cdphe.state.co.us]
Sent: Tuesday, September 14, 2010 12:22 PM
To: Kevin Lewis
Subject: Thermo Power and Electric
Kevin,
I had asked for the serial numberand either the design fuel consumption rate
(gal/hr) or heat input rate (mmBtu/hr) for the emergency generator and fire
pump but I didn't get the information for either unit. Can you provide that
information?
Jackie Joyce
Permit Engineer, Operating Permit Unit
Colorado Air Pollution Control Division
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, CO 80246
Phone: (303) 692-3267
Fax: (303) 782-0278
Jackie.Joyce@state.co.us
(9/12/2010) Jackie Joyce -Thermo Power& Electric LLC Renewal Page 1
From: "Kevin Lewis" <klewis@airsci.com>
To: "'Jackie Joyce"' <JEJOYCE@cdphe.state.co.us>
CC: "'Richard Recor"' <RRecor@capitalpower.com>, "Matthew Speer" <MSpeer@cap...
Date: 9/8/2010 10:33 AM
Subject: Thermo Power& Electric LLC Renewal
Attachments: 95WE001 renew2 dop- redline.doc
Hi Jackie,
Below is the information you requested:
1. Emergency Generator and Fire pump.
Manufacture Date
Model
HP
Typical Hours of Operation per Year
Emergency Generator
1987
Cummings
V-504-F2
187
15-20
Emergency Fire Pump
1980
Detroit Diesel
V7163-7300
745
20-40
9/12/2010) Jackie Joyce -Thermo Power& Electric LLC Renewal Page 2
2. No methylene chloride paint stripping chemicals are used.
Also, included is a redline/strikeout of the permit with our comments. Most
of the comments are editorial. Two main comments are as follows:
1. The new RICE conditions
2. Portable analyzer testing and compliance
The new RICE conditions
The renewal permit contains the applicable RICE sections verbatim from 40
CFR 63. Although this makes sense from a legal perspective, it may be a
little difficult to follow by the operators. If possible, we would like
these conditions streamlined -see redline/strikeout for example changes.
Portable analyzer testing and compliance
Section I, Condition 2.3 -The current permit requires a 14-day follow-up
portable analyzer test if the initial portable analyzer test fails. If the
follow-up test also fails, then a reference method test is conducted within
45 days, which is used to determine the final compliance status. The
proposed renewal permit establishes compliance based on the initial portable
analyzer test only. This change to the permit does not allow the facility
any time to react to a failed portable analyzer test, or even to determine
if the portable analyzer test is valid. Therefore, we would prefer that
the original conditions be left intact. However, to the extent that these
conditions have to be changed, we request that the new conditions at least
require a follow-up portable analyzer test within 14 days to verify
compliance or non-compliance. See proposed redline/strikeout in the
attached file.
The proposed redline/strikeout requires a second portable analyzer within 14
days if the initial test fails. These 14 days will allow the facility to
determine if the initial failed test is due to either an invalid test or a
real emissions problem. If it is the latter, the 14 days would allow the
facility time to take corrective action, and hopefully fix the problem.
This can only be accomplished if the turbine is allowed to run (for a
limited time) to troubled shoot and fix the problem.
(9/12/2010) Jackie Joyce - Thermo Power& Electric LLC Renewal Page 3
Kevin Lewis
720-389-4213 Office
303-638-2892 Mobile
303-484-5030 Fax
Air Sciences Inc.
1301 Washington Avenue, Suite 200
Golden, CO 80401-1915
Ari. OF ' COl
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Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Thermo Power & Electric LLC
First Issued: January 1, 1999
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Thermo Power& OPERATING PERMIT NUMBER
Electric LLC
FACILITY ID: 1230126 95OPWE001
RENEWED:
EXPIRATION DATE:
MODIFICATIONS: See Appendix F of Permit
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act,25-7-101 et
sett.and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATION:
Thermo Power and Electric LLC. 510 18th Street
510 l8`"Street Greeley,Colorado 80631
Greeley,CO 80631 Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received: August 10,2009
And Additional Information Received:
Nature of Business: Cogeneration of Electricity and Steam
Primary SIC: 4931
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Richard Recor Name: Richard Recor
Title: General Manager Title: General Manager
Phone: (970)352-6700 Phone: (970)352-6700
SUBMITTAL DEADLINES
Semi-Annual Monitoring Period: EXAMPLE(January 1 -June 30,July 1—December 31)
Semi-Annual Monitoring Report: EXAMPLE(Due on Aug. 1.2006&Feb. 1,2007&subsequent years)
Annual Compliance Period: EXAMPLE(Begins January 1 to December 31)
Annual Compliance Certification: EXAMPLE(Due on February 1,2007 and subsequent years)
Note that the Semi-Annual Monitoring Reports and Annual Compliance Certifications must be received
at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the
purposes of determining the timely receipt of those reports/certifications.
TABLE OF CONTENTS:
SECTION I-General Activities and Summary 1
1. Permitted Activities - 1
2. Alternative Operating Scenarios(8/23/06 version) 2
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant
Deterioration(PSD) 4
4. Accidental Release Prevention Program(112(r)) 5
5. Compliance Assurance Monitoring(CAM) 5
6. Summary of Emission Units 5
SECTION II-Specific Permit Terms 6
1. S001/S002-Two(2)GE LM5000 Natural Gas Fired Turbines(339 MMBtu/hr each) 6
2. Portable Monitoring Requirements(6/1/06 version) 12
3. Performance Test Requirements 13
4. Continuous Parametric Monitoring and Compliance Algorithm Requirements 14
5. M001 -Diesel Fuel Fired Internal Combustion Engines 16
SECTION III-Permit Shield 22
1. Specific Non-Applicable Requirements 22
2. General Conditions 22
3. Streamlined Conditions 23
SECTION IV-General Permit Conditions 24
1. Administrative Changes 24
2. Certification Requirements 24
3. Common Provisions 24
4. Compliance Requirements 28
5. Emergency Provisions 29
6. Emission Controls for Asbestos 29
7. Emissions Trading,Marketable Permits,Economic Incentives 29
8. Fee Payment 29
9. Fugitive Particulate Emissions 30
10. Inspection and Entry 30
II. Minor Permit Modifications 30
12. New Source Review 30
13. No Property Rights Conveyed 30
14. Odor 30
15. Off-Permit Changes to the Source 31
16. Opacity 31
17. Open Burning 31
18. Ozone Depleting Compounds 31
19. Permit Expiration and Renewal 31
20. Portable Sources 31
21. Prompt Deviation Reporting 31
22. Record Keeping and Reporting Requirements 32
23. Reopenings for Cause 33
24. Section 502(6)(10)Changes 33
25. Severability Clause 34
26. Significant Permit Modifications 34
TABLE OF CONTENTS:
27. Special Provisions Concerning the Acid Rain Program 34
28. Transfer or Assignment of Ownership 34
29. Volatile Organic Compounds 34
30. Wood Stoves and Wood burning Appliances 35
APPENDIX A-Inspection Information
Directions to Plant. 1
Safety Equipment Required'
Facility Plot Plan.
List of Insignificant Activities
APPENDIX B
Reporting Requirements and Definitions
Monitoring and Permit Deviation Report -Part I 5
Monitoring and Permit Deviation Report-Part II 6
Monitoring and Permit Deviation Report-Part III 8
APPENDIX C
Format for Annual Compliance Certification Reports
APPENDIX D I
Notification Addresses
APPENDIX E I
Permit Acronyms 1
APPENDIX F 1
Permit Modifications 1
APPENDIX G I
Algorithm for NOx&CO Compliance Verification
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit#95OPWE001 Page 1
SECTION I- General Activities and Summary
Permitted Activities
1.1 This facility consists of a cogeneration facility defined under Standard Industrial Classification
4931. Electricity for sale is produced by two(2)combustion turbines and a steam turbine. Each
combustion turbine serves a generator rated at 42.5 MW (name-plate) and the steam turbine
generator is rated at 16.3 MW (name-plate). In addition to the combustion turbines, significant
emission units at this facility consist of one (1) diesel-fired engine driving an emergency
generator and one(I)diesel-fired engine driving a fire pump.
This facility is located in an area classified as attainment/maintenance for carbon monoxide
(CO). Under that classification, all SIP-approved requirements for CO will continue to apply in
order to prevent backsliding under the provisions of Section 1100)of the Federal Clean Air Act.
This Area is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as
defined in Regulation No.7,Section II.A.1.
Wyoming, an affected state is within 50 miles of the plant. Rocky Mountain National Park, a
Federal Class I designated area is within 100 kilometers of the plant.
1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 This Operating Permit incorporates the applicable requirements contained in the underlying
construction permits, and does not affect those applicable requirements, except as modified
during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements of Part B. Any revisions made using
the provisions of Regulation No. 3, Part C shall become new applicable requirements for
purposes of this operating permit and shall survive reissuance. This permit incorporates the
applicable requirements (except as noted in Section II) from the following construction permits:
87WE113-I and 87WE113-2.
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado
Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State-only enforceable conditions are: Permit Condition Number(s):
Section II, Condition 1.12.3 (opacity) and Section IV - Conditions 3.d, 3.g (last paragraph), 14
and 18(as noted)
1.5 All information gathered pursuant to the requirements of this permit is subject to the
Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions
in Section IV of this permit. Either electronic or hard copy records are acceptable.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit#95OPWE00I Page 2
2. Alternative Operating Scenarios(8/23/06 version)
The following Alternative Operating Scenario (AOS) for temporary and permanent combustion turbine
replacement and turbine component replacement has been reviewed in accordance with the requirements
of Regulation No.3.,Part A, Section IV.A,Operational Flexibility-Alternative Operating Scenarios,and
Regulation No.3, Part B,Construction Permits,and Regulation No. 3,Part D, Major Stationary Source
New Source Review and Prevention of Significant Deterioration and has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any combustion turbine replacement performed in accordance with this AOS,
and the permittee shall be allowed to perform such turbine or turbine component replacement without
applying for a revision to this permit or obtaining a new Construction Permit.
2.1 Routine Turbine Component Replacements
2.1.1 The following physical or operational changes to the turbines in this permit are not
considered a modification for purposes ofNSPS GG,NSR/PSD,or Regulation No.3:
2.1.1.1 Replacement of stator blades, turbine nozzles, turbine buckets, fuel
nozzles, combustion chambers, seals, and shaft packings, provided that
they are of the same design as the original.
2.1.1.2 Changes in the type or grade of fuel used, if the original gas turbine
installation,fuel nozzles.etc.were designed for its use.
2.1.1.3 An increase in the hours of operation (unless limited by a permit
condition).
2.1.1.4 Variations in operating loads within the turbine design specification.
2.1.1.5 Any physical change constituting routine maintenance,repair or
replacement.
2.1.2 Turbines undergoing any of the above changes are subject to all federally applicable
and state-only requirements set forth in this permit(including monitoring and record
keeping),and shall be subject to any shield afforded by this permit. If replacement of
any of the components listed in Conditions 2.1.1.1 or 2.1.1.5 above results in a
change in serial number for the turbine, a letter explaining the action as well as a
revised APEN and appropriate filing fee shall be submitted to the Division within 30
days of the replacement.
2.1.3 Note that the repair or replacement must be genuinely the same design. Except in
accordance with the Alternative Operating Scenario set forth below,the Division does
not consider that this allows for the entire replacement (or reconstruction) of an
existing turbine with an identical new one or one similar in design or function.
Rather, the Division considers the repair or replacements to encompass the repair or
replacement of components at a turbine with the same (or functionally similar)
components.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Power and Electric LLC
Colorado Operating Permit
Permit it 95OPWE001 Page 3
2.2 Turbine Replacement
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary replacement turbine. "Temporary"is defined as in the same service for operating --{Deleted:90
days or less in any 12 month period. The 270 days is the total number of days that the turbine is
in operation. If the turbine operates only part of a day,that day counts towards the Iday total. ..--{Deleted:90
Note that the compliance demonstrations made as part of this AOS are in addition to any
compliance demonstrations required by this permit.
All replacement turbines are subject to all federally applicable and state-only requirements set
forth in this permit(including monitoring and record keeping),and shall be subject to any shield
afforded by this permit.
Results of all tests and the associated calculations pursuant required by this AOS shall be
submitted to the Division within 30 calendar days of the test. Results of all tests shall be kept on
site for five(5)years and made available to the Division upon request.
The permittee shall maintain a log on-site to contemporaneously record the start and stop date of
any turbine replacement,the manufacturer,model number,horsepower, and serial number of the
turbine(s)that are replaced during the term of this permit,and the manufacturer, model number,
horsepower,and serial number of the replacement turbine.
2.2.1 The permittee may temporarily replace an existing permitted turbine provided such
replacement turbines are General Electric, Model No. LM5000 combustion turbines
without modifying this permit, so long as the emissions from the temporary
replacement turbine comply with the emission limitations for the existing permitted
turbine as determined in Section 2.3. Measurement of emissions from the temporary
replacement turbine shall be made as set forth in Section 2.3.
The permittee may temporarily replace a grandfathered turbine or a turbine that is
not subject to emission limits without modifying this permit. In this circumstance,
potential annual emissions of NO, and CO from the temporary replacement turbine
must be less than or equal to the potential annual emissions of NO,and CO from the
original grandfathered turbine or for the turbine that is not subject to emission limits,
as determined by applying appropriate emission factors(e.g.AP-42 or manufacturer's
emission factors)
2.3 Portable Analyzer Testing
The permittee shall measure nitrogen oxide(NO,) and carbon monoxide (CO) emissions in the
exhaust from the replacement turbine using a portable flue gas analyzer within seven (7)
pperating days of commencing operation of the replacement engine. -{Deleted:calendar
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All portable analyzer testing required by this permit shall be conducted using the Division's
Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's
website at:http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual or short term emission limit, the results of the tests shall be
converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year
(whichever applies) in order to monitor compliance. If a source is not limited in its hours of
operation the test results will be multiplied by the maximum number of hours in the month or
year(8760),whichever applies.
If the portable analyzer results indicate compliance with both the NOx and CO emission
limitations, in the absence of credible evidence to the contrary, the source may certify that the
turbine is in compliance with both the NOx and CO emission limitations for the relevant time
period.
An exceedance of either the NOx or CO emission limitation during the initial portable flue gas —{Formatted:Subscript
analyzer test shall require a subsequent portable analyzer test within 14 operating days of the
initial test. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible
evidence to the contrary, if the subsequent portable analyzer results fail to demonstrate
compliance with either the NOx or CO emission limitations,the turbine will be considered to be
out of compliance from the date of the portable analyzer test until a portable analyzer test
indicates compliance with both the NOx and CO emission limitations or until the turbine is taken
offl ine.
2.4 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the
installation of a new emissions unit, not"routine replacement"of an existing unit. The AOS is
therefore essentially an advanced construction permit review. The AOS cannot be used for
additional new emission points for any site; a turbine that is being installed as an entirely new
emission point and not as part of an AOS-approved replacement of an existing onsite turbine
must go through the appropriate Construction/Operating permitting process prior to installation.
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD)
3.1 This facility is categorized as a PSD major stationary source (potential to emit of NOx > 100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
(see Colorado Regulation No. 3, Part D. Sections II,A.26 and 42) or a modification which is .--{Deleted:n
major by itself(Potential to Emit> 100 tons/year)for any pollutant listed in Colorado Regulation
3, Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may
result in the application of the PSD review requirements.
3.2 This source is categorized as a NANSR major stationary source(Potential to Emit of NOx>100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
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(see Regulation No. 3,Part D,Sections II.A.26 and 42)for VOC or NOx or a modification which
is major by itself(Potential to Emit > 100 tons/year of either VOC or NOx) may result in the
application of the NANSR review requirements.
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of NANSR and PSD review regulations.
4. Accidental Release Prevention Program(112(r))
4.1 Based on the information provided by the applicant,this facility is not subject to the provisions
of the Accidental Release Prevention Program(section 112(r)of the Federal Clean Air Act).
5. Compliance Assurance Monitoring(CAM)
5.1 The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre-control emissions that
exceed or are equivalent to the major source threshold. They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in
Colorado Regulation No.3,Part C,Section XIV:
The turbines are not subject to CAM since at the time the CAM plan was required the Title V
permit specified a continuous compliance determination method (40 CFR Part 64 §
64.2(6)(1)(vi),as adopted by reference in Colorado Regulation No.3,Part C,Section XIV).
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Emission AIRS Facility Description Startup Date Pollution
Unit Stack Identifier Control Device
Number Number
S00I 001 T001 General Electric LM5000 Natural Gas Combustion ,I 988 Steam Injection 1 ---{Deleted:1992
Turbine,Rated at 339 MMBtu/hr. Serial No.474- for NOx
203.
I S002 002 T002 General Electric LM5000 Natural Gas Combustion j.988 Steam Injection -{Deleted:1992
Turbine,Rated at 339 MMBtuthr. Serial No.474- for NOx
122.
M001 N/A M001 One(I)diesel-fired engine driving an emergency Uncontrolled
generator and one(1)driving a fire pump.
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SECTION II- Specific Permit Terms
1. S001/S002-Two(2)GE LM5000 Natural Gas Fired Turbines(339 MMBtu/hr each)
(Limits are for each turbine)
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
BACT 1.1 N/A N/A N/A See Condition 1.1.
Requirements
RACT 1.2. N/A N/A N/A See Condition 1.2.
Requirements
PM 1.3. N/A 20.8 tons/yr 0.0066 lb/MMBtu Recordkeeping Monthly
and Calculation
0.11 lb/MMBtu N/A Fuel Restriction Only Natural
Gas is Used as
Fuel.
PM,( N/A N/A 0.0066 lb/MMBtu Recordkeeping Anually
VOC N/A 6.24 tons/yr 0.0021 lb/MMBtu and Calculation Monthly
SO2 1.4. 2.28 lbs/hr 10.0 tons/yr 0.0067 lb/MMBtu Recordkeeping Monthly
and Calculation
0.35 lb/MMBtu N/A Fuel Restriction See Condition
1 4.
NOx 1.5. N/A 535.5 tons/yr N/A Continuous Continuously
Parametric
Monitoring
System and
Compliance
Algorithm
100 ppmvd 4,15%oxygen at ISO Recordkeeping Monthly
conditions,on a 1-hr average and Calculation
CO 1.6. 10.27 lbs/hr 45.0 tons/yr 0.030 lb/MMBtu Portable Quarterly
Monitoring
Performance Test Every Five(5)
Years
Natural Gas 1.7 N/A 2,970 N/A Fuel Invoices Monthly
Consumption MMscf/yr
Continuous 1.8 T-44(low pressure turbine N/A Continuous Continuously
Parametric temperature),To(ambient Sensors,Meters
Monitoring temperature),Steam Injection and Recorder
System and Rate,and Fuel Use
Compliance
Algorithm
Fuel Sulfur 1.9 Not to Exceed 2.36 grains/100 scf N/A See Condition 1.9.
Content
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Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
Btu Content of 1.10. N/A N/A N/A Fuel Invoices Monthly
Natural Gas
NSPS 1.11 N/A N/A N/A As Required by Subject to
General NSPS General NSPS General
Provisions Provisions
Provisions
Opacity 1.12 Not to Exceed 20%,Except as N/A See Condition 1.12.
Provided for Below
For Certain Operational
Activities-Not to Exceed 30%,
for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
State-Only Requirement: Not
to Exceed 20%
1.1 The combustion turbines are subject to the requirements of the Prevention of Significant
Deterioration(PSD) Program. Best Available Control Technology(BACT) shall be applied for
control of Nitrogen Oxides(NOx). BACT for NOx has been determined to be steam injection
with the emission limit identified in Condition 1.5.2(Colorado Construction Permit 87WE113-1
and—2).
1.2 The combustion turbines are subject to the Reasonably Available Control Technology
Requirements(RACT)for PM and CO emissions(Colorado Regulation No.3,Part B,Section
III.D.2.a). RACT has been determined as follows:
1.2.1 RACT for CO has been determined to be good combustion practices with the short-
term(hourly) emission limit included in Condition 1.6. The turbines and associated
control equipment shall be operated and maintained in accordance with
manufacturer's requirements and good engineering practices. Such procedures and
preventative maintenance schedules shall be maintained and made available to the
Division upon request.
1.2.2 RACT for PM has been determined to be the use of natural gas as fuel. In the
absence of credible evidence to the contrary, compliance with the PM RACT
requirements is presumed provided the gas used as fuel meets the requirements in
Condition 1.9.
1.3 Particulate Matter(PM and PMi0)and VOC emissions are subject to the following requirements:
1.3.1 PM and VOC emissions from each turbine shall not exceed the annual limitations
stated above(Colorado Construction Permits 87WEI13-I and -2 as modified under
the provisions of Section I, Condition 1.3 to remove the short term (lbs/hr) limits).
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Monthly emissions from each turbine shall be calculated by the end of the subsequent
month using the above emission factors (from AP-42, Section 3.1, April 2000,Table
3.1-2a),the monthly natural gas consumption and the higher heating value of the gas
(see Condition 1.10)in the following equation:
tons/month=(EF,lbs/MMBtu)x(Natural Gas Use,MMSCF/mo)X(Heat Content of Fuel,MMBtu/MMSCFI
2000 lbs/ton
Monthly emissions from each turbine shall be used in a twelve-month rolling total
to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
1.3.2 Particulate Matter (PM) emissions from each turbine shall not exceed 0.11
Ib/MMbtu (Colorado Regulation No. I, Section III.A.1). In the absence of credible
evidence to the contrary, compliance with the particulate matter emission limits is
presumed since only natural gas is permitted to be used as fuel in the turbines.
The numeric PM standards were determined using the design heat input for each
turbine(339 mmBtu/hr)in the following equation:
PE=0.5 x(FI)-°20` where: PE=particulate standard in lbs/mmBtu
FI=fuel input in mmBtu/hr
1.3.3 Annual emissions of PM10 from each turbine,for the purposes of APEN reporting and
payment of fess shall calculated using the above emissions factors,the annual natural
gas consumption and the higher heating value of the fuel (see Condition 1.10) in the
following equation:
tons/year=(EF lbs/MMBtu)x(Natural Gas Use MMSCF/year)X(Heat Content of Fuel MMBra/MMSCF1
2000 lbs/ton
1.4 Sulfur Dioxide(SO2)emissions shall not exceed the following limitations:
1.4.1 Sulfur Dioxide emissions from each turbine shall not exceed the above limitations
(Colorado Construction Permits 87WE113-1 and-2).
1.4.1.1 In the absence of credible evidence to the contrary compliance with the
short-term (hourly) emission limit shall be presumed provided the natural
gas used as fuel meets the sulfur limit in Condition 1.9.
1.4.1.2 Compliance with annual emission limitations shall be monitored as
follows:
a. Monthly emissions from each turbine shall be calculated by the end
of the subsequent month using the emission factor(based on permitted
hourly emission limit divided by design rate of turbine (339
mmBtu/hr)), the monthly natural gas consumption and the higher
heating value of the fuel(see Condition 1.10)in the equation provided
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in Condition 1.3.1. Monthly emissions from each turbine shall be
used in a twelve-month rolling total to monitor compliance with the
annual limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
b. The natural gas used as fuel shall meet the sulfur limit in Condition
1.9.
1.4.2 Sulfur Dioxide(SO2)emissions from each turbine shall not exceed 0.35
Ibs/MMBtu,on a 3-hr rolling average(Colorado Regulation No. 1,Section
VI.B.4.c.(ii)and V I.B.2). In the absence of credible evidence to the contrary,
compliance with the SO2 limitations is presumed provided the natural gas used as fuel
meets the sulfur content requirement in Condition 1.9.
1.5 Nitrogen Oxide(NOx)emissions shall not exceed the following:
1.5.1 Nitrogen Oxide Emissions from each turbine shall not exceed the above limitations
(Colorado Construction Permits 87WE113-1 and-2,as modified under the provisions
of Section I, Condition 1.3 to remove the hourly limitation). Compliance with the
annual limitation shall be monitored using the continuous parametric monitoring
system and compliance algorithm specified in Condition 1.8. Hourly emissions
predicted by the algorithm from each turbine shall be summed to determine monthly
emissions by the end of the subsequent month. Monthly emissions shall be used in a
rolling twelve-month rolling total to monitor compliance with the annual limitation.
Each month a new twelve month total shall be calculated using the previous twelve
months data.
1.5.2 For BACT purposes,Nitrogen Oxide Emissions from each turbine shall not exceed
100 ppmvd at 15% O2 corrected to ISO Conditions, on a 1-hr average (Colorado
Construction Permits 87WE113-1 and -2). The continuous parametric monitoring
system and compliance algorithm specified in Condition 1.8 shall be used to monitor
compliance with the BACT NOx emission limit. Any hours that exceed the limitation
shall be reported on the excess emission report required by Condition 4.3.
1.5.3 Portable monitoring shall be conducted quarterly in accordance with the requirements
in Condition 2 to monitor compliance with the NOx limits in Conditions 1.5.1 and
1.5.2.
1.5.4 A performance test shall be conducted every five (5) years in accordance with the
requirements in Condition 3 to monitor compliance with the NOx limits in Conditions
1.5.1 and 1.5.2.
Note that the previous performance tests for these units were conducted on April 23,
2008.
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1.6 Carbon Monoxide (CO) emissions from each turbine shall not exceed the above limitations
(Colorado Construction Permits 87WE113-1 and-2). Compliance with the emission limitations
shall be monitored as follows:
1.6.1 The continuous parametric monitoring system and compliance algorithm specified in
Condition 1.8 shall be used to monitor compliance with the short-term (hourly) CO
emission limit. Any hours that exceed the limitation shall be reported on the excess
emission report required by Condition 4.3.
1.6.2 The emission factor listed above(based on permitted hourly emission limit divided by
design rate of turbine(339 mmBtu/hr))shall be used to calculate emissions.
Monthly emissions shall be calculated by the end of the subsequent month using the
above emission factor, the monthly natural gas consumption and the higher heating
value of the gas(see Condition 1.10)in the equation provided in Condition 1.3.1.
Monthly emissions from each turbine shall be used in a twelve-month rolling total
to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
If a reference method test is conducted under the provisions of Condition 1.6.3, and
the results of the testing show that either the NOx or CO emission rates/factors are
greater than the emission rates/factors listed above, the permittee shall apply for a
modification to this permit to reflect, at a minimum,the higher emission rates/factors
within 60 days of the completion of the reference method test.
1.6.3 Portable Monitoring shall be conducted quarterly in accordance with the provisions in
Condition 2 of this permit.
1.6.4 A performance test shall be conducted in accordance with the provisions in Condition
3 of this permit.
1.7 Natural gas consumption for each turbine shall not exceed the limitations stated above
(Colorado Construction Permits 87WE113-1 and-2). Natural gas use for each turbine shall be
measured and recorded using the continuous parametric monitoring system specified in
Condition 1.8. Monthly natural gas consumption, as determined by fuel invoices, shall be used
in a twelve-month rolling total to monitor compliance with the annual limitations. Each month a
new twelve month total shall be calculated using the previous twelve months data.
1.8 A continuous parametric monitoring system and compliance algorithm shall be installed and
operated on each turbine to measure and record the following:
1.8.1 Low pressure turbine temperature(T-44),hourly average;
1.8.2 Ambient temperature(T0),hourly average;
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1.8.3 Steam injection rate,hourly average;
1.8.4 Fuel use,hourly average;
1.8.5 Compliance check for NOx and CO emissions,for each hour of operation;and
1.8.6 NOx emissions,Ibs/hr
The continuous parametric monitoring system and compliance algorithm shall meet the
requirements in Condition 4 of this permit.
1.9 The fuel gas sulfur content shall not exceed the limitation stated above (Construction Permits
87WE113-1 and -2, as modified under the provisions of Section I, Condition 1.3 to reflect the
fuel sulfur content that the SO2 emission limits are based on). The following methods may be
used to demonstrate that the fuel gas sulfur requirement is met:
1.9.1 The demonstration shall be made using the gas quality characteristics in a current,
valid purchase contract,tariff sheet or transportation contract for the gaseous fuel;or
1.9.2 Representative fuel sampling data provided number and frequency of sampling data
meets the requirements of either sections 2.3.1.4 or 2.3.2.4 of Appendix D of 40 CFR
Part 75.
1.10 The Btu content of the natural gas used to fuel these turbines shall be determined monthly from
supplier supplied fuel invoices. Calculation of emissions as specified in Conditions 1.3.1,
1.4.1.2.a and 1.6.2 shall be based on the most recent fuel invoice. Calculation of annual
emissions as specified in Condition 1.3.3 shall be based on the average Btu content for the year.
The Btu content used in emission calculations shall be based on the lowest gross heating value of
the fuel.
1.11 Regulation No.6,Part A,Subpart A.General Provisions applies as follows:
1.11.1 No article,machine,equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes,but is not limited to,the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere (40 CFR Part 60 Subpart A §
60.12).
1.11.2 At all times, including periods of startup, shutdown, and malfunction owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
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procedures,and inspection of the source(Colorado Construction Permits 113-1 and-2
and 40 CFR Subpart A§60.11(d)).
1.12 The turbines are subject to the following opacity requirements:
1.12.1 Except as provided for in Condition 1.12.2 below, no owner or operator of a source
shall allow or cause the emission into the atmosphere of any air pollutant which is in
excess of 20% opacity (Colorado Construction Permits 87WE113-1 and —2 and
Colorado Regulation No. 1, Section II.A.I). This opacity standard applies to each
turbine.
1.12.2 No owner or operator of a source shall allow or cause to be emitted into the
atmosphere any air pollutant resulting from the building of a new fire,cleaning of fire
boxes, soot blowing, start-up, process modifications, or adjustment or occasional
cleaning of control equipment which is in excess of 30% opacity for a period or
periods aggregating more than six(6)minutes in any sixty(60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each
turbine.
1.12.3 State-Only Requirement: No owner or operator may discharge, or cause the
discharge into the atmosphere of any particulate matter which is greater than 20%
opacity (Colorado Regulation No. 6, Part B, Section 11.C.3). This opacity standard
applies to each turbine.
This opacity standard applies at all times except during periods of startup, shutdown
and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in
Colorado Regulation No.6,Part B, Section I.A).
Note that this opacity requirement is more stringent than the opacity requirement in
Condition 1.12.2 during periods of building of a new fire, cleaning of fire boxes, soot
blowing, process modifications and adjustment or occasional cleaning of control
equipment.
In the absence of evidence to the contrary,compliance with the above opacity requirements shall
be presumed since only natural gas is permitted to be used as fuel for these turbines.
2. Portable Monitoring Requirements(6/1/06 version)
Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted
quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly
tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable
monitoring requirements do not apply.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at:
http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf
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Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For
comparison with an annual or short term emission limit, the results of the tests shall be converted to a
lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in
order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year(8760),whichever applies.
If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in
the absence of credible evidence to the contrary,the source may certify that the engine is in compliance
with both the NOx and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S.25-7-123.1 and in the absence of credible evidence to the contrary,if
the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission
limitations,the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations
or until the engine is taken offline.
For comparison with the emission rates/factors, the emission rates/factors determined by the portable
analyzer tests and approved by the Division shall be converted to the same units as the emission
rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission
rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent
testing results to the contrary(as approved by the Division),the permittee shall apply for a modification
to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion
of the test.
Results of all tests conducted shall be kept on site and made available to the Division upon request.
3. Performance Test Requirements
Performance testing shall be performed every five (5) years to monitor compliance with the NOx and
CO emission limitations in Conditions 1.5.1, 1.5.2 and 1.6. Performance testing shall be conducted in
accordance with the provisions of 40 CFR Part 60 Subpart GG § 60.335 for NOx and Method 10 (40
CFR Part 60 Appendix A)for CO or other test methods or procedures acceptable to the Division.
Note that the previous performance tests for these units were conducted on April 23,2008.
A stack testing protocol shall be submitted for Division approval at least thirty(30)calendar days prior
to any performance of the test required under this condition. No stack test required herein shall be
performed without prior written approval of the protocol by the Division. The Division reserves the
right to witness the test. In order to facilitate the Division's ability to make plans to witness the test,
notice of the date(s)for the stack test shall be submitted to the Division at least thirty(30)calendar days
prior to the test. The Division may for good cause shown,waive this thirty(30)day notice requirement.
In instances when a scheduling conflict is presented, the Division shall immediately contact the
permittee in order to explore the possibility of making modifications to the stack test schedule. The
required number of copies of the compliance test results shall be submitted to the Division within forty-
five(45)calendar days of the completion of the test unless a longer period is approved by the Division.
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Colorado Operating Permit
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4. Continuous Parametric Monitoring and Compliance Algorithm Requirements
4.1 Equipment and QA/QC Requirements
4.1.1 The monitoring and recording devices specified in Conditions 1.8.1 through 1.8.4
shall be accurate to within + 5 % and approved by the Division (Colorado
Construction Permits 87 W E 113-1 and—2).
4.1.2 The monitoring and recording devices shall be operated, maintained and calibrated in
accordance with manufacturer's requirements. Such procedures and preventative
maintenance schedules shall be maintained and made available to the Division upon
request.
4.1.3 All continuous monitoring systems and monitoring devices shall be installed such that
representative measurements of process parameters are obtained (40 CFR Part 60
Subpart A §60.13(1)).
4.1.4 A NOx and CO algorithm quality assurance/quality control plan shall be developed to
assess continued accuracy of the algorithm. Such plan shall be made available to the
Division upon request. Revisions to the plan shall be made to the plan at the request
of the Division.
4.2 General Provisions
4.2.1 The permittee shall ensure that all continuous emission monitoring systems required
are in operation and monitoring unit emissions or opacity at all times except for
monitoring system breakdowns, repairs and calibration checks (40 CFR Part 60
Subpart A§60.13(e)).
4.2.2 Alternative monitoring systems, alternative reference methods, or any other
alternatives for the required continuous monitoring systems shall not be used without
having obtained prior written approval from the appropriate agency, either Division
or the U.S. EPA. depending on which agency is authorized to approve such
alternative under applicable law. Any alternative continuous emission monitoring
systems or continuous opacity monitoring systems must be certified in accordance
with the requirements of 40 CFR Part 60 prior to use.
4.2.3 All test and monitoring equipment, methods, procedures and reporting shall be
subject to the review and approval by the appropriate agency, either the Division or
the U.S. EPA,depending on which agency is authorized to approve such items under
applicable law, prior to any official use. The Division shall have the right to inspect
such equipment, methods and procedures and data obtained at any time. The
Division may provide a witness(s)for any and all tests as Division resources permit.
4.2.4 A file suitable for inspection shall be maintained of all measurements, including
continuous monitoring system, monitoring device, and performance testing
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measurements; all continuous monitoring system performance evaluations; all
continuous monitoring system or monitoring device calibration checks; adjustments
and maintenance performed on these systems or devices; and all other information
required by applicable portions of 40 CFR Part 60 Subpart A (40 CFR Part 60
Subpart A§60.7(f),as adopted by reference in Colorado Regulation No.6,Part A).
4.2.5 Records shall be maintained of the occurrence and duration of any startup,shutdown,
or malfunction in the operation of the source; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or
monitoring device is inoperative(40 CFR Part 60 Subpart A§60.7(b)).
4.3 Recordkeeping and Reporting Requirements
4.3.1 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each calendar quarter, a report of excess
emissions for all pollutants monitored for that quarter(40 CFR Part 60 Subpart A §
60.7(c)). This report shall consist of the following information and/or reporting
requirements as specified by the Division:
4.3.1.1 The magnitude of excess emissions computed in accordance with 40 CFR
Part 60 Subpart A § 60.13(h), any conversion factor(s)used, and the date
and time of commencement and completion of each time period of excess
emissions and the process operating time during the reporting period (40
CFR Part 60 Subpart A§60.7(c)(1)).
4.3.1.2 Specific identification of each period of excess emissions that occurs
during startups, shutdowns, and malfunctions of the affected facility. The
nature and cause of any malfunction (if known), the corrective action
taken or preventative measures adopted (40 CFR Part 60 Subpart A §
60.7(c)(2)).
4.3.1.3 The date and time identifying each period during which the continuous
monitoring system was inoperative except for zero and span checks and
the nature of the system repairs or adjustments(40 CFR Part 60 Subpart A
§60.7(c)(3)).
4.3.1.4 When no excess emissions have occurred or the continuous monitoring
system(s) have not been inoperative, repaired, or adjusted, such
information shall be stated in the report (40 CFR Part 60 Subpart A §
60.7(c)(4)).
4.3.2 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each calendar quarter,a summary report for that
quarter(40 CFR Part 60 Subpart A § 60.7(c)). One summary report form shall be
submitted for each pollutant monitored. This report shall contain the information and
be presented in a format approved by the Division.
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If the total duration of excess emissions for the reporting period is less than I percent
of the total operating time for the reporting period and continuous monitoring system
(CMS) downtime is less than 5 percent of the total operating time for the reporting
period, only the summary report form shall be submitted and the excess emission
report described in Condition 4.3.1 need not be submitted unless required by the
Division(40 CFR Part 60 Subpart A§60.7(d)(l)).
If the total duration of excess emissions for the reporting period is 1 percent or greater
of the total operating time for the reporting period or the total CMS downtime for the
reporting period is 5 percent or greater of the total operating time for the reporting
period, the summary report form and the excess emission report described in
Condition 4.3.1 shall both be submitted(40 CFR Part 60 Subpart A§60.7(d)(1)).
5. M001-Diesel Fuel Fired Internal Combustion Engines
Unless otherwise specified,the requirements apply to each engine
Parameter Permit Limitations Compliance Monitoring
Condition Emission Factor
Number Short Term Long Term Method Interval
MACT ZZZZ 5.1. Change Oil and Filter N/A - See Condition 5.1.
Requirements Inspect Air Cleaner
Inspect all Hoses and Belts
SO2 5.2. 0.8 Ibs/mmBtu N/A Fuel Restriction Only Diesel
Fuel is Used
as Fuel
Opacity 5.3 Not to Exceed 20%Except as N/A EPA Method 9 See Condition
Provided for Below 5.3
For Startup-Not to Exceed
30%,for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
MACT General 5.4. N/A N/A N/A See Condition 5.4
Provisions
Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction
permit requirements in Regulation No.3,Part B.
5.1 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National
Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines",as follows:
These requirements included in this Condition 5.1 are only federally enforceable. As of the date
of revised permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart ZZZZ
promulgated on March 3,2010 have not been adopted into Colorado Regulation No. 8,Part E by
the Division and are therefore not state-enforceable. In the event that the Division adopts these
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requirements these engines will be subject to the APEN reporting and minor source permitting
requirements and these requirements will be state-enforceable.
IT WOULD BE HELPFUL IF TIFF FOLLOWING RICE CONDITIONS COULD BE
STREAMLINED. EG.,
Deleted:When do I have to comply with this
- ------ - - subpart(¢6o8595)
5.1.1 The Permittec must comply with the applicable emission limitations and operating — Deleted:If you have an existing stationary CI
limitations no later than May 3,2013.(§63.6595(a)(1)) wcE located at an area source of HAP enosslons
You
...AND SO O.N.
What emission limitations and operating limitations must I meet if I own or operate an existing
CI RICE located at an area source of HAP emissions(§63.6603)
5.1.2 If you own or operate an existing stationary CI RICE located at an area source of
HAP emissions, you must comply with the requirements in Table 2d to this subpart
and the operating limitations in Table 2b to this subpart which apply to you. (§
63.6603(a))The requirements in Table 2d that apply to these emergency CI RICE are
as follows:
5.1.2.1 Change oil and filter every 500 hours of operation or annually whichever
comes first.(Table 2d,item 4.a)
5.1.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever
comes first.(Table 2d,item 4.b)
5.1.2.3 Inspect all hoses and belts every 500 hours of operation or annually
whichever comes first,and replace as necessary.(Table 2d,item 4.c)
Notwithstanding the above requirements,the following applies:
5.1.2.4 Sources have the option to utilize an oil analysis program as described in
Condition 5.1.8 in order to extend the specified oil change requirement in
Condition 5.1.2.1.(Table 2d,footnote 1)
5.1.2.5 If an emergency engine is operating during an emergency and it is not
possible to shut down the engine in order to perform the management
practice requirements on the schedule required in Conditions 5.1.2.1
through 5.1.2.3,or if performing the management practice on the required
schedule would otherwise pose an unacceptable risk under Federal, State,
or local law,the management practice can be delayed until the emergency
is over or the unacceptable risk under Federal, State, or local law has
abated. The management practice should be performed as soon as
practicable after the emergency has ended or the unacceptable risk under
Federal, State, or local law has abated. Sources must report any failure to
perform the management practice on the schedule required and the
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Federal, State or local law under which the risk was deemed unacceptable.
(Table 2d,footnote 2)
What are my general requirements for complying with this subpart?(§63.6605)
5.1.3 You must be in compliance with the emission limitations and operating limitations in
this subpart that apply to you at all times.(§63.6605(a))
5.1.4 At all times you must operate and maintain any affected source, including associated
air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions. The
general duty to minimize emissions does not require you to make any further efforts
to reduce emissions if levels required by this standard have been achieved.
Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Division which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source. (§
63.6605(6))
What are my monitoring, installation, collection, operation, and maintenance requirements? (§
63.6625)
5.1.5 If you own or operate an existing stationary RICE with a site rating of less than 100
brake HP located at a major source of HAP emissions, an existing stationary
emergency RICE, or an existing stationary RICE located at an area source of HAP
emissions not subject to any numerical emission standards shown in Table 2d to this
subpart, you must operate and maintain the stationary RICE and after-treatment
control device (if any) according to the manufacturer's emission-related written
instructions or develop your own maintenance plan which must provide to the extent
practicable for the maintenance and operation of the engine in a manner consistent
with good air pollution control practice for minimizing emissions. (§63.6625(e))
5.1.6 If you own or operate an existing emergency stationary RICE with a site rating of less
than or equal to 500 brake HP located at a major source of HAP emissions or an
existing emergency stationary RICE located at an area source of HAP emissions,you
must install a non-resettable hour meter if one is not already installed.(§63.6625O)) _--{Deleted:g
5.1.7 If you operate a new or existing stationary engine, you must minimize the engine's
time spent at idle during startup and minimize the engine's startup time to a period
needed for appropriate and safe loading of the engine, not to exceed 30 minutes,after
which time the emission standards applicable to all times other than startup in Tables
la,2a,2c,and 2d to this subpart apply.(§63.6625(h))
5.1.8 If you own or operate a stationary engine that is subject to the work, operation or
management practices in Condition 5.1.2.1, you have the option of utilizing an oil
analysis program in order to extend the specified oil change requirement in Condition
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5.1.2.1. The oil analysis must be performed at the same frequency specified for
changing the oil in Condition 5.1.2.1. The analysis program must at a minimum
analyze the following three parameters: Total Base Number, viscosity, and percent
water content.The condemning limits for these parameters are as follows:Total Base
Number is less than 30 percent of the Total Base Number of the oil when new;
viscosity of the oil has changed by more than 20 percent from the viscosity of the oil
when new; or percent water content (by volume) is greater than 0.5. If all of these
condemning limits are not exceeded, the engine owner or operator is not required to
change the oil. If any of the limits are exceeded, the engine owner or operator must
change the oil before continuing to use the engine. The owner or operator must keep
records of the parameters that are analyzed as part of the program, the results of the
analysis,and the oil changes for the engine.The analysis program must be part of the
maintenance plan for the engine.(§63.66250))
How do I demonstrate continuous compliance with the emission limitations and operating
limitations? (§63.6640)
5.1.9 If you own or operate an existing emergency stationary RICE with a site rating of less
than or equal to 500 brake HP located at a major source of HAP emissions, a new
emergency stationary RICE with a site rating of more than 500 brake HP located at a
major source of HAP emissions that was installed on or after June 12, 2006, or an existing emergency stationary RICE located at an area source of HAP emissions,you
must operate the engine according to the conditions described below.(§63.6640(f))
5.1.9.1 For owners and operators of emergency engines,any operation other than
emergency operation, maintenance and testing, and operation in non-
emergency situations for 50 hours per year, as permitted in this section, is
prohibited.(§63.6640(t)(I))
5.1.9.2 There is no time limit on the use of emergency stationary RICE in
emergency situations.(§63.6640(1)(2))
5.1.9.3 You may operate your emergency stationary RICE for the purpose of
maintenance checks and readiness testing, provided that the tests are
recommended by Federal,State or local government,the manufacturer,the
vendor, or the insurance company associated with the engine.
Maintenance checks and readiness testing of such units is limited to 100
hours per year. The owner or operator may petition the Administrator for
approval of additional hours to be used for maintenance checks and
readiness testing. but a petition is not required if the owner or operator
maintains records indicating that Federal, State, or local standards require
maintenance and testing of emergency RICE beyond 100 hours per year.
(§63.6640(f)(3))
5.1.9.4 You may operate your emergency stationary RICE up to 50 hours per year
in non-emergency situations, but those 50 hours are counted towards the
100 hours per year provided for maintenance and testing.The 50 hours per
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year for non-emergency situations cannot be used for peak shaving or to
generate income for a facility to supply power to an electric grid or
otherwise supply power as part of a financial arrangement with another
entity; except that owners and operators may operate the emergency
engine for a maximum of 15 hours per year as part of a demand response
program if the regional transmission organization or equivalent balancing
authority and transmission operator has determined there are emergency
conditions that could lead to a potential electrical blackout, such as
unusually low frequency, equipment overload, capacity or energy
deficiency,or unacceptable voltage level. The engine may not be operated
for more than 30 minutes prior to the time when the emergency condition
is expected to occur, and the engine operation must be terminated
immediately after the facility is notified that the emergency condition is no
longer imminent. The 15 hours per year of demand response operation are
counted as part of the 50 hours of operation per year provided for non-
emergency situations.The supply of emergency power to another entity or
entities pursuant to financial arrangement is not limited by this Condition
5.1.9.4, as long as the power provided by the financial arrangement is .--{Deleted:9
limited to emergency power.(§63.6640(f)(4))
What records must I keep? (¢63.6655)
5.1.10 You must keep records of the maintenance conducted on the stationary RICE in order
to demonstrate that you operated and maintained the stationary RICE and after-
treatment control device(if any)according to your own maintenance plan if you own
or operate an existing stationary CI RICE located at an area source of HAP emissions
subject to management practices as shown in Conditions 5.1.2.1 through 5.1.2.3. (§
63.6655(e)and§63.6655(e)(3))
5.1.11 If you own or operate an existing emergency stationary CI RICE located at an area
source of HAP emissions that does not meet the standards applicable to non-
emergency engines, you must keep records of the hours of operation of the engine
that is recorded through the non-resettable hour meter. The owner or operator must
document how many hours are spent for emergency operation, including what
classified the operation as emergency and how many hours are spent for non-
emergency operation. If the engines are used for demand response operation, the
owner or operator must keep records of the notification of the emergency situation,
and the time the engine was operated as part of demand response.(§ 63.6655(f)and§
63.6655(1)(2))
5.2 Sulfur Dioxide (SO2) emissions shall not exceed 0.8 lbs/mmBtu (Colorado Regulation No. 1,
Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the
SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in
these engines.
5.3 Opacity of emissions from the engine shall not exceed the following:
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5.3.1 Except as provided for in Condition 5.3.2 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess of
20%opacity(Colorado Regulation No. 1,Section II.A.I).
5.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere
any air pollutant resulting from startup which is in excess of 30%opacity for a period or
periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1,Section II.A.4).
Compliance with these limitations shall be monitored by conducting opacity observations in
accordance with EPA Reference Method 9 as follows:
5.3.3 An engine startup period of less than 60 minutes shall not require a startup opacity
observation. If the engine startup period is greater than 60 minutes, one opacity
observation shall be made for each consecutive 4 hour period of startup during daylight
hours. In addition,a record shall be kept of the date and time the engine started and when
it was shutdown.
5.3.4 Continued operation of the engine after the completion of the startup period shall require
monthly opacity observations. If the startup and operation of the engine lasts less than a
total of 4 hours from engine start to engine stop,in any one day no opacity observations
are required for that day.
5.3.5 If no opacity observations are made pursuant to Conditions 5.3.3 and 5.3.4 above,then an
opacity observation shall be conducted annually.
5.3.6 All opacity observations shall be performed by an observer with current and valid
Method 9 certification. Results of Method 9 readings and a copy of the certified Method
9 reader's certificate shall be kept on site and made available to the Division upon
request.
5.4 These engines are subject to the requirements in 40 CFR part 63 Subpart A "General
Provisions",as adopted by reference in Colorado Regulation No.8,Part E, Section I as specified
in 40 CFR Part 63 Subpart ZZZZ §63.6665. These requirements include, but are not limited to
the following:
5.4.1 Prohibited activities in§63.4(a).
5.4.2 Circumvention in§63.4(6)
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SECTION III- Permit Shield
Regulation No.3,5 CCR 1001-5,Part C, §§ I.A.4,V.D.,&XIII.B and§25-7-114.4(3)(a),C.R.S.
1. Specific Non-Applicable Requirements
Based on the information available to the Division and supplied by the applicant,the following parameters and
requirements have been specifically identified as non-applicable to the facility to which this permit has been
issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit
issuance. In addition, this shield does not protect the source from any violations that occur as a result of any
modification or reconstruction on which construction commenced prior to permit issuance.
Emission Unit Non-Applicable Requirement Justification
Description&
Number
S003 Colorado Regulation 1,III.A-Particulate The Cooling Tower at this facility does not fall under the
Emissions regulated categories for particulate emissions.
SOD l/S002 Colorado Regulation No. 1,IV. Gaseous fuel is the only fuel burned in these turbines.
S001/5002 40 CFR Part 64,as adopted by reference in These units are exempt from CAM under 40 CFR Part 64§
Colorado Regulation No.3,Part C,Section 64.2(b)(I)(vi),as adopted by reference in Colorado Regulation
XIV. No.3,Part C,Section XIV because at the time the CAM plan
was required the Title V permit specified a continuous
compliance determination method.
All Colorado Regulation No.6,Part B,IV.- Emission Units at this facility do not fall under the regulated
Performance Standards for New Sources of categories for this requirement.
Sulfur Dioxide
S003 40 CFR 63,Subpart Q Cooling Tower This facility does not use chromium-based water treatment
(Colorado Regulation No.8,Part A, chemicals.
NESHAPs,Subpart Q)
All 40 CFR 72,Federal Acid Rain Permitting The facility is exempted from the acid rain regulations by 40
Provisions(Colorado Regulation No. 18) CFR 72 6(1))(5). The facility is a qualifying facility that entered
into a power purchase agreement for more than 15%of its total
capacity prior to November 15, 1990.
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning
enforcement in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time of permit issuance:
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2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a)of the
federal act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to
§ 25-7-111(2)(1), C.R.S., or the ability of the Administrator to obtain information pursuant to §
114 of the federal act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause
pursuant to Regulation No.3,Part C, §XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source
subsequent to permit issuance.
3. Streamlined Conditions
The following applicable requirements have been subsumed within this operating permit using the pertinent
streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the
listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed
requirements.
Permit Condition Streamlined(Subsumed)Requirements
Section II,Condition Regulation No.6,Part B,Section II.D.3.b[sulfur dioxide standard]-State-only
1.4.2. Requirement
Section II,Condition 40 CFR Part 60 Subpart GG§60.332(6)(as adopted by reference in Regulation No.6,Part
1.5.2 A,Subpart GG)[Nitrogen Oxide emissions shall not exceed 115 ppmvd at 15%oxygen and
ISO standard day conditions]
Section II,Condition 1.8 40 CFR Part 60 Subpart GG§60.334(a),as adopted by reference in Colorado Regulation
No.6,Part A[continuous monitoring system to measure and record the fuel consumption
rate and ratio of water to fuel]
Section II,Condition 1.8 40 CFR Part 60 Subpart GG§60.334(j)(1)(iii),as adopted by reference in Colorado
Regulation No.6,Part A[NOx excess emission reporting]
Section It,Condition 1.9 40 CFR Part 60 Subpart GG§60.333(as adopted by reference in Colorado Regulation No.
6,Part A[SO2 standards—150 ppmvd or 0.8 weight percent sulfur in fuel]
Section II,Condition 1.9 40 CFR Part 60 Subpart GG§60.334(h)(3),as adopted by reference in Colorado Regulation
No.6,Part A[source shall monitor the sulfur content of the fuel]
Section IV,Conditions 40 CFR Part 60 Subpart Dc§60 48c(i),as adopted by reference in Colorado Regulation 6,
21.b&c Part A[retain records for two(2)years]
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SECTION IV- General Permit Conditions
3/23/10 version
Administrative Changes
Regulation No.3 5 CCR 1001-5 Part A,ff Ill.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes
that are described in Regulation No.3,Part A,§Lat. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No.3 5 CCR 1001-5,Part C §§III B 9. V.C.16.a.&e.and V.C.17.
a. Any application,report,document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the
truth,accuracy and completeness of such form,report or certification stating that,based on information and belief
formed after reasonable inquiry,the statements and information in the document are true,accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status ofthe source:
(iii) whether compliance was continuous or intermittent,
(iv) method(s)used for determining the compliance status ofthe source,currently and over the reporting
period;and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status ofthe
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to§ 112(r)of the federal act,the
permittee shall certify its compliance with that requirement,the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation.5 CCR 1001-2$ ILA.,IIB.,IL C_ It E,11.P..11.1,and E.7
a. To Control Emissions Leaving Colorado
When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause
the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving
State.
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b. Emission Monitoring Requirements
The Division may require owners or operators of stationary air pollution sources to install,maintain,and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s)
and furnish the Division a written report of the results of such test(s)in order to determine compliance with
applicable emission control regulations.
Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance;or
(iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations
promulgated by the Commission.
Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility.The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s).Operations during period of
startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as
follows:
(i) Sampling ports adequate for test methods applicable to such facility;
(ii) Safe sampling platform(s);
(in) Safe access to sampling platform(s);and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be
conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining
compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply.In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other
circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined
using the arithmetic mean of the results of the two other runs.
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Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted.
d. Affirmative Defense Provision for Excess Emissions during Malfunctions
Note that until such time as the U.S. EPA approves this provision into the Colorado State Implementation Plan
(SIP),it shall be enforceable only by the State.
An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil
penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be
relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility
must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that:
(i) The excess emissions were caused by a sudden,unavoidable breakdown of equipment,or a sudden,
unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of
the owner or operator;
(ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and
avoided,or planned for,and could not have been avoided by better operation and maintenance practices;
(iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being
exceeded;
(iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum
extent practicable during periods of such emissions;
(v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible),
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed,contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or
maintenance;
(ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator,and shall not constitute an additional applicable requirement,and
(x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality
standards established in the Commissions'Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible,but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits,including,but not limited to,new source performance standards and national emission standards
for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip)
limits or permit limits that have been set taking into account potential emissions during malfunctions,including,but
not necessarily limited to,certain limits with 30-day or longer averaging times,limits that indicate they apply during
malfunctions,and limits that indicate they apply at all times or without exception.
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e. Circumvention Clause
A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use
of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals
an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
f Compliance Certifications
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation
Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement, the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or
maintenance;
(iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the
bypass was unavoidable to prevent loss of life,personal injury,or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed,contemporaneous operating logs or other relevant evidence;and,
(viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator,and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall
submit written quarterly notification following the initial occurrence of the excess emissions.The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief
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The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants,or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-
four hours. In addition,an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration(PSD)increments.
In making any determination whether a source established an affirmative defense,the Division shall consider the
information within the notification required above and any other information the Division deems necessary,which
may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No.3 5 CCR 1001-5,Part C.§§III.C.9.,V.C.11 &16.d.and§25-7-122.1(2) C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and
Regulation No.3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the
state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens
under§304 of the federal act. Any such violation of the federal act,the state actor regulations implementing either
statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination,revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified,revoked,reopened,and reissued,or terminated for cause. The filing of any request by
the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned
changes or anticipated noncompliance does not stay any permit condition,except as provided in§§X.and Xl.of
Regulation No.3,Part C.
d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the
Division,any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the
permittee shall also furnish to the Division copies of records required to be kept by the permittee,including
information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on
which it is based.
f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division,progress reports which contain the following:
(i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and
dates when such activities,milestones,or compliance were achieved:and
(ii) an explanation ofwhy any dates in the schedule of compliance were not or will not be met,and any
preventive or corrective measures adopted.
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g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No.3 5 CCR 1001-5,Part C,§VII
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency"does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation,or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission
limitation if the pemrittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated:
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards,or other requirements in the permit;and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency,and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency,any steps taken to mitigate emissions,and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No.8,5 CCR 1001-10,Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8,Part B,"asbestos control."
7. Emissions Trading,Marketable Permits,Economic Incentives
Regulation No.3.5 CCR 1001-5 Part C,§V.C.13.
No permit revision shall be required under any approved economic incentives,marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S.§§25-7-114.1(6)and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S.§25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 9151 day after the
date of invoice,unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S.§25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
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c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S.§25-7-114.1(6)for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. I,5 CCR 1001-3 &lit D_I_
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere,in accordance with the provisions of Regulation No. I,§IUD.I.
10. Inspection and Entry
Regulation No.3 5 CCR 1001-5,Part C $V C.16.b.
Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution
Control Division,or any authorized representative,to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is
conducted,or where records must be kept under the terms of the permit,
b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit,
c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment),
practices,or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or
applicable requirements,any substances or parameters.
11. Minor Permit Modifications
Regulation No.3 5 CCR 1001-5,Part C SS X.&XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No,3,5 CCR 1001-5,Part B
The permittee shall not commence construction or modification of a source required to be reviewed under the New Source
Review provisions of Regulation No.3,Part B,without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No.3,5 CCR 1001-5,Part C ff V_C.II.d.
This permit does not convey any property rights of any sort,or any exclusive privilege.
14. Odor
Regulation No.2 5 CCR 1001-4,Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
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15. Off-Permit Changes to the Source
Regulation No.3,5 CCR 1001-5 Part C &XII.B.
The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an
applicable requirement,but not otherwise regulated under the permit,and the emissions resulting from the change,including
any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit The permit shield shall not apply to any off-permit change.
16. Opacity
Regulation No.I.5 CCR 1001-3 &§1 II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1,§§I.-II.
17. Open Burning
Regulation No.9 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No.9.
18. Ozone Depleting Compounds
Regulation No. 15.5 CCR 1001-17
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I.,11.C.,II.D.,III.,IV.,V.of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No.3,5 CCR 1001-5 Part C,§§111.B.6.,IV.C. V.C.2.
a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision,supplementing,or deletion,incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No.3,5 CCR 1001-5,Part C,§II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in
location.
21. Prompt Deviation Reporting
Regulation No.3,5 CCR 1001-5,Part C §V.C.7.6.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit,the probable cause of such deviations,and any corrective actions or preventive measures
taken.
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"Prompt"is defined as follows:
a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit;or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of
deviations will be submitted based on the following schedule'.
(i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements,the report shall be made within 24
hours of the occurrence,
(ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements,the report shall be made within 48
hours;and
(iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d.below.
c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone
(303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. /Explanatory note: Notification
by telephone or facsimile must spec fy that this notification is a deviation report for an Operating Permit.] A
written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be
submitted within 10 working days of the occurrence. All deviations reported under this section shall also be
identified in the 6-month report required above.
"Prompt reporting" does not constitute an exception to the requirements of"Emergency Provisions" for the purpose of
avoiding enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No.3,5 CCR 1001-5,Part A 6 11.:Part C,*1 V.C.6. V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain
compliance monitoring records that include the following information:
(i) date,place as defined in the Operating Permit,and time of sampling or measurements;
(ii) date(s)on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis,and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5)years from the date of the monitoring sample,measurement,report or application. Support information,for this
purpose,includes all calibration and maintenance records and all original strip-chart recordings for continuous
monitoring instrumentation,and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12)month period,as well as compliance certifications for the past five(5)years on-site at all times. A permittee
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shall make available for the Air Pollution Control Division's review all other records of required monitoring data
and support information required to be retained by the permittee upon 48 hours advance notice by the Division.
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every
six(6)months,unless an applicable requirement,the compliance assurance monitoring rule,or the Division requires
submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly
identified in such reports.
e. The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or altering
any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted,
unless such source is exempt from the APEN filing requirements of Regulation No.3,Part A,§II.D. A revised
APEN shall be filed annually whenever a significant change in emissions,as defined in Regulation No.3,Part A.
II.C.2.,occurs;whenever there is a change in owner or operator of any facility,process,or activity;whenever new
control equipment is installed;whenever a different type of control equipment replaces an existing type of control
equipment;whenever a permit limitation must be modified,or before the APEN expires. An APEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required,the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No.3 5 CCR 1001-5 Part C &XIII.
a. The Air Pollution Control Division shall reopen,revise,and reissue Operating Permits;permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No.3,Part C,§Ill.,except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years,unless the effective date of the requirements is later than
the date on which the permit expires,or unless a general permit is obtained to address the new requirements;
whenever additional requirements(including excess emissions requirements)become applicable to an affected
source under the acid rain program;whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days'advance notice to the permittee of its intent to reopen the permit,except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Section 502(6)(10)Changes
Regulation No.3 5 CCR 1001-5.Part C.ti XII.A.
The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of
each such notice given to its Operating Permit.
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25. Severability Clause
Regulation No.3 5 CCR 1001-5,Part C.5 V.C.10.
In the event of a challenge to any portion of the permit,all emissions limits, specific and general conditions, monitoring,
record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable.
26. Significant Permit Modifications
Regulation No.3 5 CCR 1001-5 Part C&111.9.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit"requirements)without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation,to the address listed in Item I in Appendix D of this permit. If the permittee chooses to
use the"Combined Construction/Operating Perrnit"application procedures of Regulation No.3,Part C,then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No.3,5 CCR 1001-5 Part C.8§V GL b.&8
a Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall
be incorporated into the permit and shall be federally enforceable.
•
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the
regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited.
28. Transferor Assignment of Ownership
Regulation No.3 5 CCR 1001-5 Part C.5 II.C.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit,responsibility,coverage,and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
29. Volatile Organic Compounds
Regulation No.7 5 CCR 1001-9 88 III&V.
a For sources located in an ozone non-attainment area or the Denver Metro Attainment Maintenance Area,all storage
tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support structures,and
pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened,
actuated,or used for necessary and proper activities(e.g.maintenance). Such opening,actuation,or use shall be
limited so as to minimize vapor loss.
Detectable vapor loss shall be determined visually,by touch,by presence of odor,or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Testing shall be conducted as in Regulation No.7,Section VIII.C.3.
b. Except when otherwise provided by Regulation No.7,all volatile organic compounds,excluding petroleum liquids,
transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be
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transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom.
c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology(RACT)is utilized.
d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in
Colorado Regulation No.7,Section VI,shall permit gasoline to be intentionally spilled,discarded in sewers,stored
in open containers,or disposed of in any other manner that would result in evaporation.
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 PS IA actual conditions are exempt from the provisions of paragraph b,
above.
30. Wood Stoves and Wood burning Appliances
Regulation No.4,5 CCR 1001-6
The permittee shall comply with the provisions of Regulation No.4 concerning the advertisement,sale,installation,and use
of wood stoves and wood burning appliances.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division
Colorado Operating Permit
Appendices
OPERATING PERMIT APPENDICES
A - INSPECTION INFORMATION
B - MONITORING AND PERMIT DEVIATION REPORT
C - COMPLIANCE CERTIFICATION REPORT
D - NOTIFICATION ADDRESSES
E - PERMIT ACRONYMS
F - PERMIT MODIFICATIONS
G - ALGORITHM FOR NOx & CO COMPLIANCE VERIFICATION
*DISCLAIMER:
None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as otherwise provided in the permit and is presented to
assist the source,permitting authority, inspectors, and citizens.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
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Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 1
APPENDIX A-Inspection Information
Directions to Plant:
The plant is adjacent to the northwest corner of UNC Campus, next to active railroad tracks and just
north of existing UNC Steam Plant in Greeley.
Safety Equipment Required:
None Listed
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on September 29, 1994 with the source's
Title V Operating Permit Application.
List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the understanding of
the facility layout. Since there is no requirement to update such a list,activities may have changed since
the last filing.
Insignificant activities and/or sources of emissions as submitted in the application are as follows:
Diesel forklift
Diesel storage tank,for generator
Diesel storage tank,for fire pump
Five(5)indoor chemical storage tanks
Sodium Hypochlorite storage tank
Three(3)oil lubrication system vents,for Turbine#1
Three(3)oil lubrication system vents,for Turbine#2
Oil lubrication system vent,for steam turbine
Cooling Tower(S003)
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Colorado Operating Permit Appendix A
Inspection Information Page 2
This Page left Intentionally Blank
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Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 1
APPENDIX B
Reporting Requirements and Definitions
with coda we.2/20/07
Please note that,pursuant to 113(c)(2)of the federal Clean Air Act,any person who knowingly:
(A) makes any false material statement,representation,or certification in,or omits material information
from,or knowingly alters,conceals,or fails to file or maintain any notice,application,record,report,
plan,or other document required pursuant to the Act to be either filed or maintained(whether with
respect to the requirements imposed by the Administrator or by a State);
(B) fails to notify or report as required under the Act;or
(C) falsifies,tampers with,renders inaccurate,or fails to install any monitoring device or method required to
be maintained or followed under the Act shall,upon conviction,be punished by a fine pursuant to title
18 of the United States Code,or by imprisonment for not more than 2 years,or both. If a conviction of
any person under this paragraph is for a violation committed after a first conviction of such person under
this paragraph,the maximum punishment shall be doubled with respect to both the fine and
imprisonment.
The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes
a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification;or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits.
All required reports must be certified by a responsible official.
Report#1:Monitoring Deviation Report(due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six
months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements
must be clearly identified in such reports.
For purposes of this operating permit,monitoring means any condition determined by observation,by data from
any monitoring protocol, or by any other monitoring which is required by the permit as well as the
recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate
monitoring,fuel analyses.and operational or control device parameter monitoring.
Report#2:Permit Deviation Report(must be reported"promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from permit
requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of
Operating Permit Number:95OPWE00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 2
such deviations, and any corrective actions or preventive measures taken. All deviations from any term or
condition of the permit are required to be summarized or referenced in the annual compliance certification.
For purposes of this operating permit,"malfunction"shall refer to both emergency conditions and malfunctions.
Additional discussion on these conditions is provided later in this Appendix.
For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set
forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or
otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For
example,quarterly Excess Emission Reports required by an NSPS or Regulation No. I,Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes
of this operating permit are any of the following:
(1) A situation where emissions exceed an emission limitation or standard contained in the permit;
(2) A situation where process or control device parameter values demonstrate that an emission limitation
or standard contained in the permit has not been met;
(3) A situation in which observations or data collected demonstrates noncompliance with an emission
limitation or standard or any work practice or operating condition required by the permit;or,
(4) A situation in which an excursion or exceedance as defined in 40CFR Part 64(the Compliance
Assurance Monitoring(CAM)Rule)has occurred.(only if the emission point is subject to CAM)
For reporting purposes,the Division has combined the Monitoring Deviation Report with the Permit Deviation
Report. All deviations shall be reported using the following codes:
1=Standard: When the requirement is an emission limit or standard
2=Process: When the requirement is a production/process limit
3=Monitor: When the requirement is monitoring
4=Test: When the requirement is testing
5=Maintenance: When required maintenance is not performed
6=Record: When the requirement is recordkeeping
7=Report: When the requirement is reporting
B=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring(CAM)Rule)has occurred.
9=Other: When the deviation is not covered by any of the above categories
Report#3:Compliance Certification(annually,as defined in the permit)
Submission of compliance certifications with terms and conditions in the permit,including emission limitations,
standards,or work practices,is required not less than annually.
Compliance Certifications are intended to state the compliance status of each requirement of the permit over the
certification period. They must be based,at a minimum,on the testing and monitoring methods specified in the
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 3
permit that were conducted during the relevant time period. In addition,if the owner or operator knows of other
material information(i.e. information beyond required monitoring that has been specifically assessed in relation
to how the information potentially affects compliance status),that information must be identified and addressed
in the compliance certification. The compliance certification must include the following:
• The identification of each term or condition of the permit that is the basis of the certification;
• Whether or not the method(s)used by the owner or operator for determining the compliance
status with each permit term and condition during the certification period was the method(s)
specified in the permit. Such methods and other means shall include,at a minimum,the methods
and means required in the permit. If necessary,the owner or operator also shall identify any
other material information that must be included in the certification to comply with section
113(c)(2)of the Federal Clean Air Act,which prohibits knowingly making a false certification or
omitting material information;
• The status of compliance with the terms and conditions of the permit,and whether compliance
was continuous or intermittent. The certification shall identify each deviation and take it into
account in the compliance certification. Note that not all deviations are considered violations.' •
• Such other facts as the Division may require,consistent with the applicable requirements to
which the source is subject,to determine the compliance status of the source.
The Certification shall also identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance
Assurance Monitoring(CAM)Rule)has occurred.(only for emission points subject to CAM)
Note the requirement that the certification shall identify each deviation and take it into account in the
compliance certification.Previously submitted deviation reports, including the deviation report submitted at the
time of the annual certification,may be referenced in the compliance certification.
Startup,Shutdown,Malfunctions and Emergencies
Understanding the application of Startup, Shutdown,Malfunctions and Emergency Provisions,is very important
in both the deviation reports and the annual compliance certifications.
Startup,Shutdown,and Malfunctions
Please note that exceedances of some New Source Performance Standards(NSPS) and Maximum Achievable
Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be
considered to be non-compliance since emission limits or standards often do not apply unless specifically stated
in the NSPS. Such exceedances must,however,be reported as excess emissions per the NSPS/MACT rules and
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
' For example,given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes
an exception and/or special circumstances relating to that same event.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 4
confident of the information related to those deviations when making compliance determinations since they are
subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available
Control Technology(PACT)sources,but are not applied in the same fashion as for NSPS and MACT sources.
Emergency Provisions
Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense
against enforcement action if they are properly reported.
DEFINITIONS
Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution
control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are
caused in part by poor maintenance or careless operation are not malfunctions.
Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process
equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily
caused by poor maintenance, careless operation, or any other preventable upset condition or preventable
equipment breakdown shall not be considered malfunctions.
Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of
the source, including acts of God, which situation requires immediate corrective action to restore normal
operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to
unavoidable increases in emissions attributable to the emergency. An emergency shall not include
noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance,
careless or improper operation,or operator error.
Operating Permit Number:95OP W E00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 5
Monitoring and Permit Deviation Report -Part I
1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the
Division as set forth in General Condition 21. The Table below must be completed for all equipment or
processes for which specific Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for describing
periods of monitoring and permit deviations,or malfunction or emergency conditions as indicated in the
Table below. One Part II Form must be completed for each Deviation. Previously submitted reports
(e.g.EER's or malfunctions)may be referenced and the form need not be filled out in its entirety.
FACILITY NAME: Thermo Power and Electric,Inc.
OPERATING PERMIT NO: 95OPWE001
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations noted Deviation Malfunction/Emergency
During Period?' Code' Condition Reported
During Period?
Operating
Permit Unit ID Unit Description YES NO 2851in YES NO
S001 General Electric LM5000 Natural Gas
Combustion Turbine,Rated at 339 MMBtu/hr,
equipped with Steam Injection for NOx
control. Serial No.474-203.
S002 General Electric LM5000 Natural Gas
Combustion Turbine,Rated at 339 MMBtufhr,
equipped with Steam Injection for NOx
control. Serial No.474-122.
M001 One(I)diesel fired engine driving an
emergency generator and one(I)diesel fired
engine driving a fire-pump
General Conditions
Insignificant Activities
See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred
shall be based on a reasonable inquiry using readily available information.
'Use the following entries as appropriate:
1=Standard: When the requirement is an emission limit or standard
2=Process: When the requirement is a production/process limit
3=Monitor: When the requirement is monitoring
4=Test: When the requirement is testing
5=Maintenance: When required maintenance is not performed
6=Record: When the requirement is recordkeeping
7=Report: When the requirement is reporting
8=CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64(the Compliance Assurance
Monitoring(CAM)Rule)has occurred.
9=Other: When the deviation is not covered by any of the above categories
Operating Permit Number:95OPWE00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 6
Monitoring and Permit Deviation Report-Part II
FACILITY NAME: Thermo Power and Electric, Inc.
OPERATING PERMIT NO: 95OPWE00l
REPORTING PERIOD:
Is the deviation being claimed as an: Emergency Malfunction N/A
(For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration(start/stop date&time)
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Malfunctions/Emergencies Reported(if applicable)
Deviation Code Division Code QA:
SEE EXAMPLE ON THE NEXT PAGE
Operating Permit Number:95OPWE00 I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 7
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04-6/30/06
Is the deviation being claimed as an: Emergency Malfunction XX N/A
(For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control-Unit XXX
Operating Permit Condition Number Citation
Section II,Condition 3.1 -Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1730 4/10/06
END- 18004/10/06
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Malfunction/Emergencies Reported(if applicable)
5/30/06 to A.Einstein,APCD
Deviation Code Division Code QA:
Operating Permit Number:95OP WE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 8
Monitoring and Permit Deviation Report-Part III
REPORT CERTIFICATION
SOURCE NAME:Thermo Power and Electric,Inc.
FACILITY IDENTIFICATION NUMBER: 1230126
PERMIT NUMBER:95OPWE001
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as
defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be
packaged with the documents being submitted.
STATEMENT OF COMPLETENESS
I have reviewed the information being submitted in its entirety and, based on information and belief
formed after reasonable inquiry,I certify that the statements and information contained in this submittal
-are true,accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly,as defined in Sub-Section 18-
1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is
guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7
122.1,C.R.S.
Printed or Typed Name Title
Signature of Responsible Official Date Signed
Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this
permit. No copies need be sent to the U.S.EPA.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 1
APPENDIX C
Format for Annual Compliance Certification Reports
ver 2/20/07
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S.
EPA annually based on the effective date of the permit. The Table below must be completed for all equipment
or processes for which specific Operating Permit terms exist.
FACILITY NAME: Thermo Power and Electric, Inc.
OPERATING PERMIT NO: 95OPWE001
REPORTING PERIOD:
1. Facility Status
During the entire reporting period,this source was in compliance with ALL terms and conditions contained
in the Permit, each term and condition of which is identified and included by this reference. The method(s)
used to determine compliance is/are the method(s)specified in the Permit.
With the possible exception of the deviations identified in the table below, this source was in compliance
with all terms and conditions contained in the Permit, each term and condition of which is identified and
included by this reference, during the entire reporting period. The method used to determine compliance for
each term and condition is the method specified in the Permit, unless otherwise indicated and described in the
deviation report(s). Note that not all deviations are considered violations.
Operating Unit Description Deviations Monitoring Was Compliance Continuous
Permit Reported Method per or Intermittent?'
Unit ID Permit?'
Previous Current YES NO Continuous Intermittent
S001 General Electric LM5000 Natural
Gas Combustion Turbine,Rated at
339 MMBtu/hr,equipped with Steam
Injection for NOx control. Serial No.
474-203.
S002 General Electric LM5000 Natural
Gas Combustion Turbine,Rated at
339 MMBtu/hr,equipped with Steam
Injection for NOx control. Serial No.
474-122.
M001 One(1)diesel fired engine driving an
emergency generator and one(I)
diesel fired engine driving a fire-
pump
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 2
Operating Unit Description Deviations Monitoring Was Compliance Continuous
Permit Reported I Method per or Intermittent?'
Unit ID Permit?'
Previous Current YES NO Continuous Intermittent
General Conditions
Insignificant Activities"
If deviations were noted in a previous deviation report, put an "X" under"previous". If deviations were noted in the current
deviation report(i.e. for the last six months of the annual reporting period),put an"X"under"current". Mark both columns if both
apply.
2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the
permit. If it was not,mark "no"and attach additional information/explanation.
•
' Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent
Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance
has occurred.
NOTE:
The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the
'absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance
for the duration of the reporting period. Therefore, if a source I)conducts all of the monitoring and recordkeeping required in its
permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not
indicate non-compliance,and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then
the Responsible Official can certify that the emission point(s)in question were in continuous compliance during the applicable time
period.
°Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 3
II. Status for Accidental Release Prevention Program:
A. This facility is subject is not subject to the provisions of the Accidental
Release Prevention Program(Section 112(r)of the Federal Clean Air Act)
B. If subject:The facility is is not in compliance with all the
requirements of section 112(r).
1. A Risk Management Plan will be has been submitted to the
appropriate authority and/or the designated central location by the required date.
III. Certification
All information for the Annual Compliance Certification must be certified by a responsible official as defined in
Colorado Regulation No. 3,Part A, Section 1.B.38. This signed certification document must be packaged with
the documents being submitted.
I have reviewed this certification in its entirety and, based on information and belief formed after
reasonable inquiry, I certify that the statements and information contained in this certification are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6),
C.R.S.,makes any false material statement,representation,or certification in this document is guilty of a
misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S.
Printed or Typed Name Title
Signature Date Signed
NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit.
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix D
Notification Addresses Page 1
APPENDIX D
Notification Addresses
I. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B I
4300 Cherry Creek Drive S.
Denver,CO 80246-1530
ATTN:Jim King
2. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement,Compliance and Environmental Justice
Mail Code 8ENF-T
U.S.Environmental Protection Agency,Region VIII
1595 Wynkoop Street
Denver,CO 80202-1129
Permit Modifications,Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Air and Radiation Programs,8P-AR
U.S.Environmental Protection Agency,Region VIII
1595 Wynkoop Street
Denver,CO 80202-1129
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 1
APPENDIX E
Permit Acronyms
Listed Alphabetically:
AIRS- Aerometric Information Retrieval System
AP-42 - EPA Document Compiling Air Pollutant Emission Factors
APEN- Air Pollution Emission Notice(State of Colorado)
APCD- Air Pollution Control Division(State of Colorado)
ASTM- American Society for Testing and Materials
BACT- Best Available Control Technology
BTU- British Thermal Unit
CAA- Clean Air Act(CAAA=Clean Air Act Amendments)
CCR- Colorado Code of Regulations
CEM- Continuous Emissions Monitor
CF- Cubic Feet(SCF=Standard Cubic Feet)
CFR- Code of Federal Regulations
CO- Carbon Monoxide
COM- Continuous Opacity Monitor
CRS- Colorado Revised Statute
EF- Emission Factor
EPA- Environmental Protection Agency
FI- Fuel Input Rate in Lbs/mmBtu
FR- Federal Register
G- Grams
Gal- Gallon
GPM- Gallons per Minute
HAPs- Hazardous Air Pollutants
HP- Horsepower
HP-HR- Horsepower Hour(G/HP-HR=Grams per Horsepower Hour)
LAER- Lowest Achievable Emission Rate
LBS- Pounds
M- Thousand
MM- Million
MMscf- Million Standard Cubic Feet
MMscfd- Million Standard Cubic Feet per Day
N/A or NA- Not Applicable
NOx- Nitrogen Oxides
NESHAP- National Emission Standards for Hazardous Air Pollutants
NSPS- New Source Performance Standards
P- Process Weight Rate in Tons/Hr
PE- Particulate Emissions
PM- Particulate Matter
PM10 - Particulate Matter Under 10 Microns
Operating Permit Number:95OPWE001 E001 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 2
PPM Parts Per Million
PPMV Parts Per Million,by Volume
PPMVD Parts Per Million,by Volume,Dry
PSD- Prevention of Significant Deterioration
PTE- Potential To Emit
RACT- Reasonably Available Control Technology
SCC- Source Classification Code
SCF- Standard Cubic Feet
SIC- Standard Industrial Classification
SO2- Sulfur Dioxide
TPY- Tons Per Year
TSP- Total Suspended Particulate
VOC- Volatile Organic Compounds
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix F
Permit Modifications Page 1
APPENDIX F
Permit Modifications
DATE OF TYPE OF SECTION DESCRIPTION OF REVISION
REVISION MODIFICATION NUMBER,
CONDITION
NUMBER
Operating Permit Number:95OPWE00I First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix G
Algorithm Page 1
APPENDIX G
Algorithm for NOx&CO Compliance Verification
•
Operating Permit Number:95OPWE001 First Issued: 1/1/99
Renewed: DRAFT
STATE OF COLORADO
Bill Ritter,Jr.,Governor
Martha E. Rudolph, Executive Director oF•cot
A.� o�
Dedicated to protecting and improving the health and environment of the people of Colorado 7, -- � t0
* �
4300 Cherry Creek Dr. S. Laboratory Services Division `,
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6928 rave
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado
of Public Health
http://www.cdphe.state.co.us and Environment
August 4, 2010
Mr. Richard Recor
General Manager
Thermo Power and Electric, LLC
510 18th Street
Greeley, CO 80631
SUBJECT: Draft Renewal Operating Permit for Thermo Power and Electric, LLC —Greeley Facility
Dear Mr. Recor:
Enclosed please find a draft of the renewal operating permit for your facility as well as a copy of the
technical review summary document. Please review and submit any comments you may have
concerning the modified draft operating permit. Following our review of your comments, we will send
the draft permit out for a 30-day Public Comment period and then to EPA for their 45-day review period.
The regulations also require that the applicant receive written notice of their right to a formal hearing
before the Colorado Air Quality Control Commission at the same time that the Public Comment packet
goes out. You will receive a separate letter containing that information.
This draft renewal permit contains the modifications that you requested in your renewal application
received on August 10, 2009. The permit was also revised to be more consistent with recently issued
permits, correct errors, omissions and discrepancies identified during inspections and/or review of the
renewal application and incorporate EPA comments made on other operating permits for similar
sources. The changes are summarized in the technical review document for the renewal permit.
While you are reviewing this permit, please be aware of the following:
1. Since the original issuance of this permit, EPA has promulgated National Emission Standards
for Hazardous Air Pollutant Emissions (NESHAP) for reciprocating internal combustion engines
(RICE) located at area sources and Standards of Performance (NSPS) for both compression
ignition and spark ignition engines: These requirements apply to both new and existing engines
engines and apply to any size engine, many of which could otherwise be considered
insignificant activities. Therefore please address the following issues related to these
requirements:
a.) Existing Engines. The insignificant activity list in your current permit indicates that there is
a stand-by diesel generator and a diesel fire pump. Revisions to the RICE MACT were
published on March 3, 2010 which apply to existing (commenced construction or
reconstruction before June 12, 2006) compression ignition engines (all sizes) located at
area sources and therefore, this engine is subject to the RICE MACT. Under the "catch-all"
provisions in Colorado Regulation No. 3, Part C, Section II.E, sources that are subject to any
federal or state applicable requirement such as a MACT standard cannot be considered an
insignificant activity. As a result, these engines have been removed from the insignificant
Mr. Richard Recor, Thermo Power and Electric, LLC August 4, 2010
Draft Renewal Operating Permit Page 2
activity list in Appendix A of the permit and are now included in Section II of the permit.
Please provide the make, model, serial number and hourly fuel or heat input rate (e.g.,
gal/hr or mmBtu/hr) for these engines.
b.) New Engines. Please indicate whether you have any engines that would meet the following
requirements:
Requirements Applicability Date Engine Type/Size
40 CFR Part 63 Subpart ZZZZ Constructed and/or Both Compression Ignition and
reconstructed after 6/12/06 Spark Ignition, all sizes
40 CFR Part 60 Subpart IIII Construction commenced Compression ignition, all sizes
(engine ordered) after 7/11/05,
engine manufactured after
4/1/06.
40 CFR Part 60 Subpart JJJJ Construction commenced Spark Ignition, all sizes
(engine ordered) after 6/12/06,
engine manufactured after
7/1/07*
*7/1/07 is the earliest manufactured date for which NSPS requirements apply, the manufactured date
varies depending on size and type of engine.
2. EPA promulgated National Emission Standards for Hazardous Air Pollutants for Paint Stripping
and Miscellaneous Surface Coating Operations at Area Sources (40 CFR Part 63 Subpart
HHHHHH) on January 9, 2008. Since the Thermo Power and Electric, Inc. — Greeley facility is
not a major source of hazardous air pollutant (HAP) emissions, these rules potentially apply.
The Division believes that any spray coating of motor vehicles and mobile equipment and spray
application of coatings that contain target HAPS that may occur at this facility would meet the
definition of facility maintenance and would therefore, not be subject to the requirements in 40
CFR Part 63 Subpart HHHHHH. However, we cannot determine whether any paint stripping
activities at this facility would be subject to these requirements. Please indicate whether any
paint stripping chemicals used at your facility include methylene chloride.
We would like you to review this permit and respond to the items identified above by September 8,
2010. Feel free to call me at (303) 692-3267 if you have any further questions.
Sincerely,
Jacqueline Joyce,
Permit Engineer
Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
Enclosures
cc: Kevin Lewis, Air Sciences, Inc., via e-mail
Thermo Power & Electric , LLC
510 18th Street, Greeley, Colorado 80631, (970) 352-6700 , Fax(970) 352-6767
August 6, 2009
Ms. Jacqueline Joyce
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permit Unit
Stationary Source Program
APCD — 55-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Subject: Operating Permit Number 95OPWE001 Renewal
Dear Ms. Joyce:
With this submittal Thermo Power& Electric LLC is applying for the renewal of the operating
permit number 95OPWE001, which expires on January 1, 2011.
No changes are being requested for the operating permit. Therefore, as per your discussions with
Air Sciences Inc. only form 2000-800 signed by a responsible official is attached in quadruplicates
(one original and three copies).
We appreciate your continued assistance with these matters. If you have any questions, please do
not hesitate to call Kevin Lewis of Air Sciences Inc. at 303-988-2960, Ext. 213 or myself at 970-
352-6700, Ext. 11.
Sincerely,
For Thermo Power & Electric LLC
Richard A. Recor
General Manger
Greeley Energy Facility
Attachment
TPJ 300
RAR: 9056
Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name:Therrno Power&Electric LLC Facility Identification Code:CO 1230126
I. ADMINISTRATION
This application contains the following forms: 1-1 Form 2000-100,Facility Identification
riForm 2000-1(11,Facility Plot Plan
▪ Forms 2000-102,-102A,and-102B,Source and Sile Descriptions
IL EMISSIONS SOURCE DESCRIPTION Total Number
of This Form
This application contains the following forms(one ri Form 2000-200,Stack Identification
form for each facility boiler,printing operation,etc.):
Form 2000-301),Boiler or Furnace Operation
• Form 2000-301,Storage Tanks
• Form 2000-302,Internal Combustion Engine
n Form 2000-303,Incineration
nForm 2000-304.Printing Operations
• Form 2000-305,Painting and Coating Operations
nForm 2000-306,Miscellaneous Processes
n Form 2000-307,Glycol Dehydration Unit
III. AIR POLLUTION CONTROL. Total Number
SYSTEM of This Form
This application contains the following forms- [] Ferns 2000-400,Miscellaneous
n Form 2000-401.Condensers
nForm 21100-402,Adsorhers
nForm 200(1-403 Catalytic or Thermal Oxidation
II Form 2000-404.Cyclones/Settling Chambers
II Form 2000-405,Electrostatic Precipitators
riForm 200O406-Wet Collection Systems
piForm 2000-407,Baghouses/Fahric Filters
IV- COMPLIANCE Total Number
DEMONSTRATION of This Form
This application contains the following fortes(one ri Form 2000-50(1,Compliance Fern flea turn-Monitoring and Reporting
for each facility boiler,printing operation,etc.):
n Form 20110-50 I,Continuous Emission Monitoring
Form 2000-502,Periodic Emission Monitoring Usi sg Portable Monitors
riForm 2000-503.Control System Parameters or Operation Parameters of a Pt oress
• Form 2000-51)4,Monitoring Maintenance Procedures
n Form 2000-505,Stack Testing
nFarm 2000-506,Fuel Sampling and Analysis
nForm 2000-507,Reeordkeeping
n Form 2000-501,Other Methods
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V. EMISSION SUMMARY AND Total Number
COMPLIANCE CERTIFICATION of This Form
This application contains the following forms n Form 2000-600,Emission Unit Hazardous Air Pollutants
quantifying emissions,certifying compliance with
applicable requirements,and developing a
compliance plan
n Form 2000-601,Emission Unit Criteria Air Pollutants
I I Form 2000-602,Facility Hazardous Air Pollutants
fi Form 2000-603,Facility Criteria Air Pollutants
n Form 2000-604,Applicable Requirements and Status of Emission Unit
n Form 2000-605.Permit Shield Protection Identification
• Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule
Form 2000-607,Plant-Wide Applicable Requirements
Form 2000-608,Plant-Wide Compliance Plan-Commitments and Schedule
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief famed after reasonable inquiry, I certify that the statements
and information contained in this application arc true,accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only)
I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements.
I certify that the facility described in this air pollution permit application is fu ly in compliance with all applicable requirements,except
for the following emissit us unit(s):
•
(list all non-complying units)
WARNING: Any person who knowingly,as defined in§ IS-I-501(6),C.R.S.,makes any false material statement,representation,or certification
in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with Ike provisions of§25-
7 122.1,C.R.S.
Printed or Typed Name Title
Richard A. Recor General Manager
Signature , J) (/ /////o Date Signed
—7 G, / L-,c-.f � /-f'.--G��.s- `u/Lis
93
•
Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Thermo Power&Electric LLC Facility Identification Code:CO 1230126
VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements
and information contained in this application are true,accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check Dne box only)
0 I certify that the facility described in this air pollution permit application is fitly in compliance w ith all applicable requirements.
I certify that the facility described in this air pollution permit application is fu ly in compliance w.th all applicable requirements,except
for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in§18-1-501(6),C.R.S.,makes any false material statement,representation,or certification
in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-
7 122.1,C.R.S.
Printed or Typed Namc Title
Richard A Recur General Manager
Signature - Dale Signed
•
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B I
4300 CHERRY CREEK DRIVE SOUTH
DENVER,CO 80246-1530
94
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